Plaintiff filed a complaint against her former employer claiming sexual harassment pursuant to the Illinois Human Rights Act. The trial court granted summary judgment in favor of the defendant. Plaintiff appealed, arguing that the evidence demonstrated that she suffered third-party sexual harassment due to the culmination of customer sexual harassment that was severe and pervasive enough to create a hostile work environment and that the defendant failed to promptly implement reasonable corrective measures. The appellate court reversed and remanded, finding that summary judgment was not proper because a reasonable jury could conclude that the measures taken in response to the plaintiff’s claims were not reasonable corrective. (ODEN JOHNSON and TAILOR, concurring)
Illinois Appellate Court
Civil Court
Sexual Harassment