has not left the trial judge without guidance in determining whether a plaintiff has met the “reasonable person” test. The Watson panel stated the generally accepted proposition that “a ‘single isolated instance’ of employment discrimination is insufficient as a matter of law to support a finding of constructive discharge.” Watson, 823 F.2d at 361, citing, Nolan, 686 F.2d at 813-14 (held that evidence of four incidents of differential treatment over two years was sufficient to create a genuine issue of fact for trial); Satterwhite, 744 at 1381-82 (“courts which have considered the question [of constructive discharge] are reluctant to predicate a finding of constructive discharge solely on the fact of employment discrimination.”); see also, Clark v. Marsh, 665 F.2d 1168 (D.C.Cir.1981) (<HOLDING>). In order to prevail in a Title YII
holding prima facie case of discrimination includes showing of adverse employment action constructive discharge could satisfy element of adverse employment action but there was no constructive discharge where evidence did not support that discrimination rather than actual performance problems prompted reprimands and poor evaluations holding that in order to sustain an action for constructive discharge the plaintiff must show that the conduct resulting in the resignation violated a virginia public policy embodied in an existing statute holding that in order to sustain death sentence as a matter of fundamental fairness the jury must find that the aggravating factors outweigh the mitigating factors and this balance must be found beyond a reasonable doubt recognizing that a constructive discharge claim and a hostile work environment claim are not equivalent because a constructive discharge claim imposes a higher standard holding that the mere fact of discrimination sans aggravating factors would not sustain a constructive discharge action