Gates v. Board of Education of the City of Chicago

Gates testified that his supervisor, Rivera, addressed him with the N‐word twice, and once threatened to write up his “black ass.” The district court granted the employer summary judgment on Gates’s claim for a racially hostile work environment under Title VII of the Civil Rights Act, 42 U.S.C. 2000e‐2, stating that Gates faced a high bar, “as ‘[t]he workplace that is actionable is one that is ‘hellish.’” The court found that Rivera’s comments were not severe or pervasive enough to rise to the level of a hostile work environment. The Seventh Circuit reversed in part. The district court erred in applying the “hellish” standard and failed to focus on the difference in Seventh Circuit hostile environment cases between having the plaintiff’s co‐workers show racial hostility and having the plaintiff’s supervisor show racial hostility, especially in using poisonous racial epithets. View "Gates v. Board of Education of the City of Chicago" on Justia Law