A female tenant lived in an apartment managed by the landlord’s male resident manager. The resident manager entered the tenant’s apartment in her absence, without her knowledge or permission, and removed some of the tenant’s lingerie. When the tenant discovered the personal invasion and burglary, she made a demand on the landlord for compensation for the resident manager’s actions, claiming the landlord was liable for his resident manager’s sexual conduct related to the tenant since the landlord has a duty to the tenant to provide a residence free of sexual harassment. The landlord rejected the tenant’s demand, claiming the resident manager’s one act of personal invasion did not constitute sexual harassment since sexual harassment requires a repeated pattern of unwanted sexual attention. A California court of appeals held the landlord was not liable for the resident manager’s actions as sexual harassment since the resident manager’s action was a single act of personal invasion without physical or verbal contact, rather than a repeated pattern of perverse and severe sexual violence or threatened violence. [Ramirez v. Wong (October 6, 2010) 188 CA4th 1480]