A day care center manager alleged that she was fired for complaining about her boss’ opposition to hiring male teachers. She is entitled to a trial because she may have been discharged for opposing a discriminatory employment practice.

A prison guard “was simply embarrassed on a handful of occasions over a period of four years by … boorish behavior … and … a dumb joke ” Because the incident’s were infrequent and difficult for the employer to remedy since they were anonymous, the award was reversed.