Employment — hostile work environment

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U.S. Court of Appeals for the 7th Circuit

Civil

Employment — hostile work environment

Where the employer promptly acted in response to the employee’s complaints of racially offensive graffiti, summary judgment was properly granted to the employer on the employee’s hostile work environment claim.

“Even though the graffiti never resurfaced after the threat to terminate offenders, Muhammad insists that Caterpillar should have done more to identify who was responsible for the graffiti and to punish all coworkers who harassed him. But Title VII requires only that employers take action reasonably calculated to stop unlawful harassment; that requirement does not necessarily include disciplining the employees responsible for past conduct. See Porter v. Erie Foods Int’l, 576 F.3d 629, 637 (7th Cir. 2009)(‘In assessing the corrective action, our focus is not whether the perpetrators were punished by the employer, but whether the employer took reasonable steps to prevent future harm.’); Lapka v. Chertoff, 517 F.3d 974, 984–85 (7th Cir. 2008). Given that Caterpillar’s prompt response halted the harassment that Muhammad brought to its attention, the company is not liable under Title VII for not doing more to hunt down the guilty coworkers for punishment.”

Affirmed.

12-1723 Muhammad v. Caterpillar, Inc.

Appeal from the United States District Court for the Central District of Illinois, McCuskey, J., Rovner, J.