(1) she is a qualified individual with a disability; (2) she was subjected to harassment; (3) that the harassment was based on her disability; (4) that the harassment was so severe or pervasive that it altered the condition of employment; and (5) that the harassment may be imputed to the employer. See Fox v. General Motors Corp., 247 F.3d 169 (4th Cir.2001). Courts have granted summary judgment on such claims because the comments and behavior alleged by plaintiffs failed to be so pervasive or severe as to alter the conditions of their employment and therefore constitute an adverse employment action by employer. This applies equally to cases involving disabilities due to mental impairment as to cases of physical impairment. See Henry v. Guest Services, Inc., 902 F.Supp. 245 (D.D.C.1995) (<HOLDING>); McClain v. Southwest Steel Co., 940 F.Supp.
recognizing a hostile work environment claim under section 1983 recognizing hostile work environment discrimination in ada context holding that coworkers cartoon ridiculing plaintiffs depression does not support a hostile work environment claim recognizing that the elements of title vii sexually hostile work environment claims apply to icra sexually hostile work environment claims holding that a viable hostile work environment claim requires an environment that a reasonable person would find hostile or abusive