How much is enough to create a hostile environment?

The facts were simple: plaintiff meets with her boss, the President of the company. In that one meeting he requests sex three times: a request for oral sex, that she participate in a threesome, and that she call him for phone sex. She refused all three. The district court finds that the conduct, occurring only within a few minutes and one time, was not pervasive enough to create a hostile environment and grants summary judgment. The Seventh Circuit reversed, sending it back for a jury trial. It points out that the test is 'severe or pervasive', either one will do, both are not required. It also held that although "infrequent, [President's] alleged outright solicitation of numerous sex acts from [plaintiff] is considerably more "severe" than the type of "occasional vulgar banter, tinged with sexual innuendo" that has previously been deemed to fall short of the hostile workplace standard." Quantock v. Shared Marketing Services, Inc. (7th Cir. 12/12/02) [pdf] Clearly, there is less than a bright line for judges and litigants to follow.