; (16) some lower court decisions have treated severe or pervasive as a threshold for liability, when the relevant inquiry is whether the harassing conduct actually altered the terms, conditions, or privileges of employment; (17) some lower court decisions further have interpreted the severe or pervasive language in the Meritor decision so narrowly as to recognize only the most egregious conduct as unlawful, despite Congress’ intent that title VII of the Civil Rights Act of 1964 afford a broad scope of protection from discrimination; (18) examples of decisions that use the erroneous analysis described in paragraphs (15) through (17) in the context of harassment on the basis of sex include— (A) Singleton v. Department of Correctional Education, 115 Fed. Appx. 119 (4th Cir. 2004); (B) Black v. Zaring Homes, Inc., 104 F.3d 822 (6th Cir. 1997); (C) Weiss v. Coca-Cola Bottling Co., 990 F.2d 333 (7th Cir. 1993); (D) Rickard v. Swedish Match North America, Inc., 773 F.3d 181 (8th Cir. 2014); (E) Mitchell v. Pope, 189 F. Appx. 911 (11th Cir. 2006); and (F) Brooks v. City of San Mateo, 229 F.3d 917 (9th Cir. 2000); (19) lower courts have made similar erroneous decisions in the context of harassment on the basis of race, national origin, age, and disability such as in Crawford v. Medina General Hospital, 96 F.3d 830 (6th Cir. 1996), Shaver v. Independent Stave Co., 350 F.3d 716 (8th Cir. 2003), and Motley v. Parker-Hannifan Corp., No. 1: 94–CV–639 (W.D. Mich. 1995); (20) in contrast, other lower court decisions applying the Meritor case and its progeny have appropriately recognized that a wide range of harassing behavior may alter the terms, conditions, or privileges of employment, with no single type, frequency, or duration of conduct required to make a showing of severe or pervasive harassment