7th Circuit Reinstates Hostile Environment Claim, Rejects ‘Hellish’ Standard

Mealey's (March 7, 2019, 11:14 AM EST) -- CHICAGO — A Seventh Circuit U.S. Court of Appeals panel on Feb. 20 reinstated an employee’s hostile work environment claim based on racial epithets allegedly used by his supervisor, finding that the District Court erred in relying on the “hellish” standard, established in Perry v. Harris Chernin, Inc., and failed to consider the difference between racial hostility by a co-worker and racial hostility by a supervisor (Fred Gates v. Board of Education of the City of Chicago, No. 17-3143, 7th Cir., 2019 U.S. App. LEXIS 4920)....