• The degree and type of language and insult that filled the environment before and after [plaintiff] arrived.
• The reasonable expectations of [plaintiff] upon entering the environment.
• The frequency of the offensive conduct.
• The severity of the conduct.
• The effect of the working environment on [plaintiff’s] mental and emotional well-being.
• Whether the conduct was unwelcome, that is, conduct [plaintiff] regarded as unwanted or unpleasant.
• Whether the conduct was pervasive.
• Whether the conduct was directed toward [plaintiff].
• Whether the conduct was physically threatening or humiliating.
• Whether the conduct was merely a tasteless remark.
• Whether the conduct unreasonably interfered with [plaintiff's] work performance.
It is not enough that the work environment was generally harsh, unfriendly, unpleasant, crude or vulgar to all employees. In order to find a hostile work environment, you must find that [plaintiff] was harassed because of [his/her] age. The harassing conduct may, but need not be age-based in nature. Rather, its defining characteristic is that the harassment complained of was linked to [plaintiff’s] age. The key question is whether [plaintiff], as a person of [plaintiff’s age] was subjected to harsh employment conditions to which substantially younger employees were not.
It is important to understand that, in determining whether a hostile work environment existed at the [employer’s workplace] you must consider the evidence from the perspective of a reasonable person of [plaintiff’s age] in the same position. That is, you must determine whether a reasonable person of [plaintiff’s age] would have been offended or harmed by the conduct in question. You must evaluate the total circumstances and determine whether the alleged harassing behavior could be objectively classified as the kind of behavior that would seriously affect the psychological or emotional well-being of a reasonable person of [plaintiff’s age]. The reasonable person of [plaintiff’s age] is simply one of normal sensitivity and emotional make-up.
