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Intentional Infliction of Emotional Distress-Employment

By: WISCONSIN LAW JOURNAL STAFF//June 17, 2024//

Intentional Infliction of Emotional Distress-Employment

By: WISCONSIN LAW JOURNAL STAFF//June 17, 2024//

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7th Circuit Court of Appeals

Case Name: Nikkolai Anderson v. Mott Street

Case No.: 23-2765

Officials: Scudder, St. Eve, and Kirsch, Circuit Judges.

Focus: Intentional Infliction of Emotional Distress-Employment

Nikkolai Anderson, a former host at Mott Street, alleged sexual harassment, discrimination, and retaliation following her termination. During her time at Mott Street, Anderson’s performance fell short and her behavior was deemed inappropriate, including negative interactions with guests and a disregard for restaurant policies. Multiple negative customer reviews pinpointed Anderson as the source of rudeness. After her dismissal, Anderson filed a lawsuit citing violations of Title VII of the Civil Rights Act of 1964 and intentional infliction of emotional distress under Illinois law.

The Northern District of Illinois ruled in favor of Mott Street, granting summary judgment. The court determined that Anderson’s claim for intentional infliction of emotional distress was time-barred and concluded that she failed to present sufficient evidence to support her Title VII allegations. Anderson appealed the decision regarding her Title VII claims.

The Seventh Circuit upheld the district court’s ruling. It found no factual disputes regarding the severity or pervasiveness of the alleged hostile work environment. Additionally, Anderson couldn’t establish an appropriate comparator or challenge Mott Street’s reasons for termination, thus her sex discrimination claim was dismissed. Moreover, the court found no evidence linking Anderson’s protected activity to her termination or indicating that Mott Street’s stated reasons were pretextual, leading to the affirmation of summary judgment on her retaliation claim.

Affirmed.

Decided 06/13/24

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