Footnote 79

See id.; see also Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 134 (2000) ("In appropriate circumstances, the trier of fact can reasonably infer from the falsity of the explanation that the employer is dissembling to cover up a discriminatory purpose."). In hostile environment (e.g., sexual harassment) cases that do not culminate in a tangible employment action, the plaintiff must show: (1) she belonged to a protected group; (2) she was exposed to unwelcome harassment; (3) the harassment was premised on her protected status; (4) it was "sufficiently severe or pervasive to alter the conditions of [her] employment and create an abusive work environment"; (5) it was "both subjectively and objectively offensive"; and (6) the employer is liable for the harasser's conduct. Abigail Cooley Modjeska, Employment Discrimination Law § 1.05, at 29 (3d ed. Supp. 2002) (footnotes omitted). See generally Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993) (applying criteria from Meritor Sav. Bank v. Vinson, 477 U.S. 57 (1986)).