EEOC v. Management Hospitality of Racine, Inc.
United States Court of Appeals for the Seventh Circuit
666 F.3d 422 (7th Cir. 2012)
Katrina Shisler and Michelle Powell (plaintiffs) worked as servers at a restaurant franchise (Racine restaurant) owned by Management Hospitality of Racine, Inc. (MHR) (defendant). Shisler worked at the Racine restaurant from March 2005 to April 2005; Powell worked there from late 2004 through June 2006. Both plaintiffs were teenagers at the time. In 2005, MHR implemented a formal policy prohibiting workplace harassment and imposing a mandatory reporting requirement on all employees. MHR charged individual restaurant managers with providing sexual harassment training to new hires, which consisted of watching a video and signing a written acknowledgement of the sexual harassment policy. In 2005, Steve Smith was the district manager for the Racine restaurant, Michelle Dahl was the general manager, and Nadia Del Rio and Rosalio Gutierrez were assistant managers. During Shisler and Powell’s respective periods of employment, Gutierrez subjected both women to frequent, sexually explicit comments, gestures, innuendo, and humiliation in front of other employees. Shisler reported the behavior to assistant manager Del Rio, who blew it off, and then to general manager Dahl, who was also dismissive. Powell complained to Dahl, who did nothing to address the complaints. The Equal Employment Opportunity Commission (EEOC) sued MHR on behalf of Shisler and Powell, alleging MHR was liable under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq., for the hostile work environment that Gutierrez created. A jury found in favor of the plaintiffs on their sexual harassment claims. MHR appealed, arguing it was not liable, because it had taken sufficient preventive and corrective measures regarding the harassment.
Rule of Law
Holding and Reasoning (Young, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.