In Holmes v. United States Steel Corporation, No. 2:23-CV-359-JEM, 2026 WL 2279295 (N.D. Ind. Aug. 6, 2026), the court, inter alia, dismissed plaintiff’s hostile work environment claim under Title VII of the Civil Rights Act of 1964, finding that plaintiff failed to “exhaust” that claim before the U.S. Equal Employment Opportunity Commission (EEOC).
From the decision:
In this case, Plaintiff’s EEOC charge did not mention harassment, any specific events that would suggest harassment or a hostile workplace, or allude in any way to a hostile work environment. To support the notion that his hostile work environment claim is exhausted, Plaintiff argues that he checked the box on the EEOC charge for continuing action and included allegations of harassment. However, as Defendant points out, there was no checkbox for continuing action on the form Plaintiff completed, there was no indication of continuing action, nor did the charge allege any specific acts of harassment or use the word “harassment.” Def. Ex. 13 p. 2-4 [DE 44-13]. The charge failed to include a detailed narrative charge with details that could be read broadly to encompass a race discrimination claim.
Merely checking the “Race” discrimination box on an EEOC charge is legally insufficient to make the charge “like or reasonably related” to specific claims, such as discriminatory discharge or harassment, if the narrative of the charge does not describe the specific conduct giving rise to those claims. Moore v. Vital Prods., 641 F.3d 253, 257 (7th Cir. 2011); see also Burton, 2024 WL 1254363, at 4 (finding that plaintiff failed to exhaust his administrative remedies for his hostile work environment claim because his EEOC charge provided no supporting facts or date). Plaintiff’s EEOC charge only stated a generalized belief of discrimination on the basis of race without describing any specific conduct, occurrences, or particular individuals. The specific acts of harassment alleged in the current lawsuit cannot be reasonably inferred from, or expected to grow out of an investigation of, a bare statement indicating a belief of racial discrimination against oneself. See Chaidez v. Ford Motor Co., 937 F.3d 998 (7th Cir. 2019); McKenzie, 92 F.3d 473. Accordingly, the Court finds that Plaintiff’s Title VII hostile workplace claim is not encompassed by his EEOC charge.
The court thus concluded that this claim is not exhausted and is procedurally barred, warranting judgment in defendant’s favor on plaintiff’s hostile work environment claim.