1317 (6th Cir.1988), the court affirmed a judgment against two university administrators who were found by the jury to have discriminatorily denied the plaintiff tenure by “imposing the additional book requirement, in distorting the outside evaluator process, and in ultimately influencing the opinions and votes of the other members of the [tenure committee].” Id. at 1327. Nothing in Gutzwiller suggests that these actions were undertaken pursuant to any official university policy or legislative mandate. In fact, by “distorting the outside evaluator process,” the administrators must necessarily have been acting in an ad hoc manner, and yet their actions were found to be violative of the plaintiffs equal protection rights. See also Risinger v. Ohio Bureau of Workers’ Compensation, supra (<HOLDING>). The Court does acknowledge that Hatcher was
recognizing hostile work environment discrimination in ada context holding that a hostile work environment is a form of discrimination that is actionable under the statute recognizing that the elements of title vii sexually hostile work environment claims apply to icra sexually hostile work environment claims recognizing a hostile work environment claim under section 1983 holding that a viable hostile work environment claim requires an environment that a reasonable person would find hostile or abusive