Court Sets an Unusually High Bar for Unlawful Harassment

How high is the bar for what qualifies as unlawful sexual harassment in the 4th Circuit? Pretty damn high, if you ask me. Consider that in Wilson v. Gaston County [pdf], the Court concluded that the following misconduct did not entitle the plaintiff to a jury trial on her sexual harassment claim:
Wilson contends that Putman began harassing her…, telling her she had a “nice ass,” sending her pictures of his genitals, asking for naked pictures in return, expressing his desire to