When people think of hostile work environment claims, sexual harassment is generally the offense that comes to mind. However, employers need to be mindful that other forms of harassment, such as race, religion, national origin, or disability, may also create a hostile work environment. The Ninth Circuit Court of Appeals recently reminded us of this in McGinest v. GTE Service Corp., 360 F.3d 1103 (9th Cir. 2004), which involved allegations of a racially hostile work environment.