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everal readers of this blog have floated the idea that Muldrow v. City of St. Louis — the Supreme Court’s recalibration of what counts as actionable harm in discrimination cases — might ripple into harassment standards. One federal appellate court recently explained why it
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oesn’t. TL;DR: The Tenth Circuit held that Muldrow v. City of St. Louis is a discrete-act decision and declined to extend it to hostile work environment