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In Spalding v. University of Washington and A.F.S.C.M.E. v. State of Washington , the U.S. Court of Appeals for the Ninth Circuit held that a plaintiff bringing a Gunther -type claim under Title VII must establish the evidence of:
Cortisol
A steroid hormone released by the adrenal glands in response to stress or low blood glucose; involved in the regulation of metabolism, immune response, and stress response.
Eustress
Positive stress which is perceived as beneficial for the experiencer, often associated with improved performance or well-being.
Activating Event
An incident in the external environment or a thought that triggers a psychological response.
General Adaptation Syndrome (GAS)
General Adaptation Syndrome (GAS) is a theoretical model describing the body's short-term and long-term reactions to stress, including stages of alarm, resistance, and exhaustion.
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