Claims of “retaliatory hostile work environment” have now been recognized by all federal circuits, including the 11th Circuit. Under Title VII, an employee may now bring a “retaliatory hostile work environment claim”in all circuits based on severe and pervasive retaliatory acts by an employer after the employee engaged in a “protected activity.” Gowski, et al. v. Peake, et al., 11th Cir., No. 09-16371 June 4, 2012.