In Kruitbosch v. Bakersfield Recovery Services, Inc., the California Court of Appeal—for the first time—addressed the issue of employer liability for harassment by a non-supervisory co-worker during non-working hours and off-premises conduct.
A coworker (Lisa Sanders) of plaintiff Steven Kruitbosch allegedly subjected him to crude sexual advances at his home and via his personal cell phone away from the premises of their employer, Bakersfield







