harassing behavior,” and (b) “the plaintiff employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Burlington Indus., Inc. v. Ellerth, 524 U.S. at 765, 118 S.Ct. 2257; accord Faragher v. City of Boca Raton, 524 U.S. at 807, 118 S.Ct. 2275; Mack v. Otis Elevator Co., 326 F.3d at 125. In this case, Petrosino asserts that Bell Atlantic is automatically vicariously liable for the gender-hostile work environment created by its employees and supervisors because that conduct culminated in two tangible adverse employment actions: her failure to receive managerial promotions and her constructive discharge. See Pennsylvania State Police v. Suders, — U.S. -, -, 124 S.Ct. 2342, 2351, 159 L.Ed.2d 204 (2004) (<HOLDING>); Mormol v. Costco Wholesale Corp., 364 F.3d
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 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 a constructive discharge would constitute a tangible employment action and prevent the employer from utilizing the affirmative defense to vicarious employer liability for sexual harassment holding that a low performance rating does not constitute constructive discharge holding that constructive discharge may qualify as a tangible employment action depriving employer of right to assert affirmative defense when a supervisors official act precipitates the constructive discharge