or promissory estoppel. The district court granted summary judgment to the state on all claims. Costilla appeals the summary judgment as to her sexual harassment claim and the intentional and negligent infliction of emotional distress claims. In October 1996, Costilla also brought a separate action against Acosta and the United States Department of Labor. Costilla remains employed at the state. ISSUES I. Does the MHRA recognize non-employee sexual harassment? II. Does the MHRA’s one-year statute of limitation bar Costilla’s claim? III. Did the district court err when it granted the state summary judgment when the state had notice in June 1993 that a non-employee, Acosta, was sexually harassing its employee, Costilla; the state took no corrective action for Supp. 500, 513 (E.D.Va.1992) (<HOLDING>), affirmed 40 F.3d 1244 (4th Cir.1994); EEOC v.
holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment holding employee had cause of action against her employers when nonemployee harassed her and employers failed to take corrective action holding employee had cause of action against city when nonemployee alderman sexually harassed employee holding employer may be hable when its employee is sexually harassed by employers patrons and employer either ratifies or acquiesces in harassment by not taking immediate andor corrective action holding if an employee does not speak as a citizen on a matter of public concern the employee has no first amendment cause of action based on his or her employers reaction to the speech