Dist. Ct. erred in granting defendant-employee’s motion for summary judgment in plaintiff-employee’s Title VII action, alleging that his workplace was racially hostile, where his supervisor addressed plaintiff by using “N-word” on two occasions and by threatening to write up his “black ass” on one occasion. Dist. Ct. erred in using “hellish” standard when finding that supervisor’s comments were not severe or pervasive enough to rise to level of hostile work environment and failed to recognize difference between co-worker’s and supervisor’s use of racial epithets in workplace. Ct. rejected defendant’s claim that instant harassment, which occurred during six-month period of four-year employment, was too infrequent to be pervasive. Moreover, result would be different if harassment had been performed by co-worker.
Federal 7th Circuit Court
Civil Court
Employment Discrimination