A recent ruling by the U.S. Court of Appeals for the Ninth Circuit rejected the notion that only conduct occurring inside the physical workplace can be actionable with respect to an employee’s unlawful harassment claims. In Okonowsky v. Garland, the Ninth Circuit reversed and remanded a district court decision granting summary judgment in favor of the employer; the lower court had dismissed the employee’s hostile work environment claim stemming from a co-worker’s social media posts, noting that the posts were not sent, displayed or shown in the workplace. The appeals court ruled that conduct outside the physical workplace “can be actionable, especially in light of the ubiquity of social media and the ready use of it to harass and bully both inside and outside of the physical workplace.”