A former officer in the Indiana Department of Correction had her claims of employment discrimination and retaliation rejected by the 7th Circuit Court of Appeals on the grounds she failed to provide supporting evidence.
Nora Chaib, a naturalized U.S. citizen born in France, appealed to the 7th Circuit after the U.S. District Court for the Southern District of Indiana, Indianapolis Division, granted summary judgment to her employer, the Indiana Department of Correction.
Chaib worked at the Pendleton Correctional Facility for nearly three years. She alleged she was subjected to harassment, not given adequate training, and shown hostility by other co-workers because of her gender or national origin.
The 7th Circuit affirmed the District Court’s ruling in Nora Chaib v. State of Indiana, 13-1680, finding the lower court had correctly granted summary judgment to the defendant on each of Chaib’s claims.
As part of its own review of Chaib’s assertion of a hostile work environment, the 7th Circuit turned to Vance v. Ball State Univ., 570 U.S. __, 133 S. Ct. 2434, 2440 (2013).
This case established that an employer is only liable for harassment from an employee’s co-workers if it was negligent in its response.
The 7th Circuit noted that after Chaib complained about her colleagues, she had no further problems with any of the officers. Moreover, she provided no evidence which indicated she had any subsequent problem with a co-worker after talking to her supervisors.
“No reasonable jury could say that her employer was negligent for failing to correct her co-workers’ behavior when it apparently corrected all of the behavior she reported,” U.S. District Court for the Northern District of Illinois Judge Frederick Kapala wrote.
Kapala was sitting on the panel by designation.