The California Fair Employment and Housing Act (FEHA) prohibits harassment based on race, religious creed, color, national origin, and ancestry, among other things. See Cal.Gov.Code. § 12940(j)(1). A working environment charged with ethnic or racial discrimination can also violate Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e, et seq. An employer has a duty to prevent and remedy instances of racial and national origin harassment. Racial slurs may constitute harassment even if made by one member to another member of the same race. racialA supervisor that makes a single racial slur may render the employer liable for creating a hostile work environment. A hostile environment may exist even if some of the hostility is directed at other workers. Claims of harassment based upon religion involve the same principles established in connection with sexual and racial harassment under Title VII and the FEHA. Hostile work environment claims have also been recognized based on disability discrimination.

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