Serving as an important reminder to employers everywhere, in Moore v. Third Judicial Circuit of Michigan, a federal district court in Michigan allowed a court administrator to pursue her retaliation claim against her employer, even as her underlying claims of sexual harassment were thrown out.  Applying a federal standard to her harassment claims, the court rejected the administrator's contention that any employment benefits were conditioned upon her submission to (or rejection of) unwelcome advances and observed that the conduct, "while perhaps awkward, impolite, and even unpleasant, [had] not risen to the level of frequency or severity to be deemed extreme."  Still, the retaliation claim survived.  Thus, the court permitted the administrator to pursue her claim that, after her complaints, several of her superiors commenced a pattern of retaliatory action toward her, including impugning her integrity and chastity, deprivation of authority previously held, barring her from accessing areas within the employer's offices, and refusal to consider her as a replacement for her supervisor following his departure.