In Pennsylvania State Police v. Suders the Supreme Court noted that in a case where discrimination in the workplace is claimed, and the employee quits and claims constructive discharge for hostile environment:

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The Supreme Court noted that an employee need not remain on the job while seeking redress for discrimination in the workplace and claiming constructive discharge for hostile environment. Constructive discharge occurs when an employer makes working conditions intolerable to the extent that a reasonable person in the employee's position would feel compelled to resign.

In Pennsylvania State Police V