Alleged Harassing Conduct Was Not Sufficiently "Severe Or Pervasive" To Constitute Actionable Harassment Under Title VII Or The ADEA
Atanus sued the federal employer, asserting Title VII claims (hostile environment harassment and disparate treatment) for race discrimination, color discrimination, gender discrimination, national origin discrimination, and retaliation. She also asserted Age Discrimination in Employment Act (ADEA) claims (disparate treatment and hostile environment harassment) for age discrimination. The trial court granted summary judgment in favor of the employer. The 7th Circuit affirmed, concluding that 1) Atanus' various disparate treatment claims failed because she produced insufficient evidence of pretext, and one of the claims did not involve an adverse employment action; 2) the alleged harassing conduct at issue was not sufficiently "severe or pervasive" to constitute actionable harassment; and 3) Atanus did not establish a prima facie case of retaliation, because she failed to show that she suffered an adverse employment action
Atanus v. Perry
The 7th Circuit Court of Appeals’ jurisdiction includes Illinois, Indiana and Wisconsin.
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