A plaintiff who wins a hostile-workplace discrimination suit is only halfway home in winning back pay: She also must show workplace conditions were so bad that she had to quit, says the 3rd U.S. Circuit Court of Appeals.

“We hold that a successful hostile work environment claim alone, without a successful constructive discharge claim, is insufficient to support a back pay award,” a three-judge panel held in Spencer v. Wal-Mart Stores Inc., No. 05-2143.

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