Employment-Seventh Circuit Rules That Plaintiff Has Established A Case Of Hostile Environment Under Title VII

In Hall v. City of Chicago, No. 11-3279 (7th Cir. 2013), plaintiff, Anna Hall , was a female plumber working in the House Drain Inspectors Division of Chicago’s Department of Sewers, in which all other nonsupport staff employees were male. Her complaint alleges that her supervisor, Gregory Johnson, created a hostile work environment under Title VII. Hall argues that, because she was female, Johnson assigned her menial work, prohibited her coworkers from interacting with her, and subjected her to verbal violence. The district court granted summary judgment to the defendant, the City of Chicago, after concluding that: (1) Johnson’s conduct was not hostile particularly in comparison to other employees’ responsibilities and (2) Hall had failed to produce evidence that Johnson’s conduct was because of her sex.

The Seventh Circuit Court of Appeals (the “Court”) reversed the district court’s decision and remanded the case back to the district court. The Court concluded that a jury could infer, from the totality of the situation, that Johnson’s deliberate isolation of Hall was sufficiently pervasive to constitute a hostile work environment in violation of Title VII. On the much closer question of whether Hall’s gender played a part in Johnson’s actions, the Court ruled that sufficient evidence to that effect can arguably be deduced from Johnson’s comments.