Mack alleged Otis Elevator should be liable for the hostile environment caused by her supervisor. The employer argued that the “supervisor” could not put the company on the hook because he could not hire, promote, reassign, change benefits or fire. The Second Circuit found that Otis could be liable because the supervisor made and oversaw work assignments.

A supervisor of a drilling rig was fired because of his age and awarded $303,392. The judgment was reversed because the former supervisor accepted lower paying hourly work after he was discriminatorily fired and failed to attempt to obtain “substantially equivalent employment” or otherwise supplement his income.

The Seventh Circuit finds that “the occasional vulgar banter, tinged with sexual innuendo, of coarse or boorish workers would be neither pervasive nor offensive enough to be actionable … The workplace that is actionable is the one that is hellish.”

A woman sought to bring a sexual harassment claim after signing a release. She argued that she did not knowingly sign the release because it did not mention “Title VII” or “federal claims.” The Court was not persuaded — case dismissed.