Stokes v. Illinois Department of Corrections

Plaintiff resigned from her employment as a contractor staffed at a state prison after she was repeatedly confronted at work for wearing allegedly inappropriate clothing and filed a lawsuit alleging violations of Title VII of the Civil Rights Act by discriminating against her based on her race and sex. The district court entered summary judgment for the defendant and plaintiff appealed. The Seventh Circuit affirmed, agreeing with the district court that under the applicable five-factor test, the defendant was not plaintiff’s joint employer and was not liable under Title VII. (HAMILTON and KIRSCH, concurring)