The Fourth Appellate District affirmed a judgment. The court held that occasional incidents of unpleasantness experienced by an employee were insufficient to support a verdict that she was subjected to “severe” or “pervasive” harassment based on gender.

Stephanie Brennan began working for advertising agency Townsend & O’Leary Enterprises, Inc. in 1991. In 2005 she resigned and sued the agency for, among other things, sexual harassment.