Case

Mary, an Asian employee with light skin tone, reports that her manager, Joan, who is a darker-skin-toned Asian, is saying negative things to Mary about the color of Mary's lighter skin. The comments include statements such as that Mary thinks she (Mary) is better than other employees, Mary is not as special as Mary thinks she is, and so on. Joan also constantly calls Mary "Sunshine" in a sarcastic way, which Mary takes as a reference to Mary's lighter skin. Mary is afraid that Joan will give her a bad evaluation. Mary is also embarrassed about having this constantly happen in front of other employees. Are Joan's actions more than just unprofessional behavior? Are they illegal?