In order to successfully support a claim of hostile work environment under Title VII, an employee must show that the offending conduct was "sufficiently severe or pervasive to alter the conditions of her employment and create an abusive work environment." One federal appellate court recently held that offensive conduct not witnessed by an individual may still contribute to that individual's claim that a workplace environment was hostile, and should be admitted as part of the employee's Title VII lawsuit. Ziskie v. Mineta, No. 06-2060 (4th Circ. November 14, 2008).