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A woman received a score of 3.7 (out of 5.0) on her first performance appraisal. She began to experience severe harassment from a coworker. She complained about it to her supervisor and the human resources department on numerous occasions. On a subsequent appraisal, she re- ceived a score of 3.04. The woman was laid off shortly thereafter, with the employer citing the fact that she had the lowest overall performance rating as the basis for the decision. She sued. What should the court decide? Why? (Winarto v. Toshiba, 274 F.3d 1276 (9th Cir. 2001))

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