The federal Second Circuit Court of Appeals ruled that a Fordham University secretary could pursue sexual harassment and retaliation claims under Title VII because of her boss's sexual activities. In Patane v. Clark, Eleanora Patane alleged that her boss, a Fordham professor, watched hardcore pornographic videos in his office (within her eyesight), and required Patane to open mail containing pornography. Patane complained to Fordham's EEO director repeatedly. After her supervisor learned of her complaints, he allegedly removed virtually all of her job functions, refused to speak with her, intentionally kept her ignorant about departmental business, and gave her negative performance evaluations.