Effective in 2019, Gov. Code 12923 “clarified” the law regarding hostile work environment sexual harassment claims. The section states that summary judgment should rarely be granted on such claims. In addition, it provides that even a single incident can be sufficient to support a hostile work environment claim “if the harassing conduct has unreasonably interfered with the plaintiff’s work performance or created an intimidating, hostile, or offensive work environment.” And, it states that a hostile work environment exists “when the harassing conduct sufficiently offends, humiliates, distresses, or intrudes upon its victim, so as to disrupt the victim’s emotional tranquility in the workplace, affect the victim’s ability to perform the job as usual, or otherwise interfere with and undermine the victim’s personal sense of well-being.” It is unnecessary for the plaintiff to show a decline in productivity; she need only show that the harassment so altered working conditions as to make it more difficult to do the job. The new statute applies to pending cases, at least to summary judgment motions or other proceedings brought after the 2019 effective date. The decision reverses a summary judgment awarded based on pre-2019 case law on hostile work environment claims.