A co-worker’s repeated stares may be enough to constitute a sexually hostile working environment according to an appellate court in California (Birschtein v. New United Motor Manufacturing Inc.) Despite the employer’s order to stay away from Birschtein, the co-worker continued to sit at a distance and stare at her for as long as five to ten minutes at a time. The court ruled that the employer’s failure to stop the staring may be seen as a failure to prevent discriminatory harassment.