to create a hostile work environment. Although the district court did not address this issue, we conclude that the incidents occur ring within the statute of limitations period (June 15, 2002 to June 15, 2005) create a genuine issue of material fact as to the existence of a hostile work environment. The ELCRA provides that an employer shall not “[discriminate against an individual with respect to employment, compensation, or a term, condition, or privilege of employment, because of religion, race, col- or, national origin, age, sex, height, weight, or marital status.” Mich. Comp. Laws Ann. § 37.2202(l)(a). Harassment in the workplace based on race or national origin is an actionable offense. See Malan v. Gen. Dynamics Land Sys., Inc., 212 Mich. App. 585, 538 N.W.2d 76, 77 (1995) (<HOLDING>). To establish a prima facie claim under the
holding harassment based on any one of the enumerated classifications in the elcra is an actionable offense holding that counsel was not ineffective in failing to request a charge on the lesserincluded offense when the evidence showed either the commission of the completed offense as charged or the commission of no offense such that the defendant was not entitled to a charge on the lesser offense holding on plainerror review an oklahoma statute for assault and battery was equivalent to the enumerated offense holding that the application of the enhancement for using a firearm in connection with another felony offense is proper only if there is a clear connection between the firearm that was used in the other offense and the one that was used in the offense of conviction holding that in determining whether a crime is a continuing offense the court must focus on the nature of the substantive offense and not on the specific characteristics of the conduct in the case at issue