Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s action, alleging that defendant subjected her to hostile work environment based in her age and race. Many of plaintiff’s identified incidents of harassment did not relate to one another to support hostile environment claim, and plaintiff’s non-selection for some of her applications for promotions/transfers involved different decision-makers. Moreover, nearly all of plaintiff’s complaints related to one-time, everyday work assignments that took place over several years that did not establish sufficiently severe or pervasive hostile environment. Also, assignments that were part of her job duties, or allegations that plaintiff’s supervisors were short-tempered, hostile, unfairly critical and/or disrespectful did not amount to objectively offensive, severe or pervasive conduct. Plaintiff also failed to show that any of alleged harassment was based on her age or race.
Federal 7th Circuit Court
Civil Court
Employment Discrimination