1. Elsa was a receptionist at Dewey, Cheatham & Howe, a well-known New York law firm. While at Dewey, Elsa was responsible for answering phones, greeting the firm's clients, reporting their presence to the attorneys, and getting them coffee. Elsa had a lot of prior experience (10 years at another law firm) and understood how to perform her duties in a professional manner. She dressed appropriately for a law firm setting (usually in a business suit), and did not wear any provocative or sexually-suggestive clothing. Often when clients would come in, they would linger at Elsa's desk, telling sexually-charged jokes or stories, etc. Some of them even went so far as to touch Elsa or themselves while making inappropriate sexual comments. One morning Elsa talked with her supervisor about what was occurring. Her supervisor was quick to remind her that it is the clients that she complained about that pay the firm's bills, including Elsa's salary. Perhaps if she played along a little more, it might lead to a salary increase, a bonus, or a promotion. Anyway, the firm does have a procedure for reporting and investigating these kinds of complaints, but it is cumbersome and is likely to take some time. In the end, the firm may weigh the value of the clients and the value of Elsa's contribution, and she may end up being terminated. The meeting ended with no official complaint filed. With a lot to consider following the meeting, Elsa returned to her duties. By mid-afternoon Elsa decided the situation at Dewey was hopeless, and she began to look at help wanted ads online. Before she left that evening, Elsa slipped her resignation letter under her supervisor's door.

What issues are raised in this fact pattern? Could this be a case of constructive discharge?