Employment Discrimination

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7^th Circuit Court of Appeals

Case Name: EEOC v. Village at Hamilton Pointe LLC

Case No.: 22-2806

Officials: Flaum, Ripple, and Scudder, Circuit Judges.

Focus: Employment Discrimination

The Equal Employment Opportunity Commission (EEOC) sued under Title VII alleging employment discrimination against black employees of Village at Hamilton Pointe, LLC, a long-term care facility in Indiana. The EEOC claimed that Hamilton Pointe and Tender Loving Care Management, LLC (TLC), which provides services to Hamilton Pointe, subjected the employees to racial harassment. The district court granted TLC’s motion for summary judgment for some employees, ruling that TLC couldn’t be considered an employer under Title VII. It also granted partial summary judgment for the claims of forty employees against Hamilton Pointe. Seven employees proceeded to a jury trial, resulting in damages awarded to one employee. The EEOC appealed both the summary judgment for TLC and Hamilton Pointe and the jury’s verdict.

The Seventh Circuit found that the EEOC didn’t prove that the employees faced a racially hostile work environment severe or pervasive enough to change their working conditions. Additionally, it found that the EEOC failed to demonstrate that TLC was a joint employer of the claimants. The court stressed that while federal law prohibits conduct severe or pervasive enough to alter employment conditions, it doesn’t guarantee that employees will have competent supervisors with strong social justice principles and personnel management skills.

Affirmed.

Decided 05/09/24

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