Employer Avoided Liability by Prompt Response to Harassment Complaint.

Although the U.S. Court of Appeals for the Seventh Circuit confirmed that racially offensive conduct by co-workers does not need to be targeted at a specific employee in order to create a hostile work environment under Title VII, the Court nonetheless found that the employer was not liable for such conduct where it responded promptly and effectively to the harassment complaints.

In Cable v. FCA US LLC, the employee complained about a co-worker’s black voodoo doll and the letters “NIG” etched into one of her workstations, as well as some other drawings that she thought were racial in nature. The Court found that because the employer promptly investigated her complaints, painted over the letters and drawings, and conducted anti-harassment training for her team members, the employer should not be held liable under Title VII and Section 1981. This case emphasizes the importance of employers responding promptly and effectively to complaints of harassment.