Kwiatkowski v. Merrill Lynch, Docket No. A-2270-06T1 (App. Div. Aug. 13, 2008), cert. denied, 197 N.J. 259 (2008)
The New Jersey Appellate Division recently held that a single comment of “stupid fag” which was made to a homosexual employee by his direct supervisor may be sufficient to create a hostile work environment, even though no one else heard the comment. The facts of the case were as follows:
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