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Bullying not actionable if not based on employee's gender

Harold Wasek sued his employer, Arrow Energy Services, Inc., claiming a civil rights violation arising out of bullying and harassment.  Apparently another oil rig worker realized he could aggravate Wasek with prurient talk and pseud-sexual physical contact.    Wasek felt the behavior originated with his acknowledgement that he was bisexual.  In any event, the Court dismissed his Elliott-Larson Civil Rights Act claim because he couldn't prove that the sexual harassment was related to his gender.
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