In Williams v. Chicago Transit Authority, 2024 WL 3455022 (N.D.Ill. July 18, 2024), the court, inter alia, held that plaintiff plausibly alleged a sex-based hostile work environment under Title VII of the Civil Rights Act of 1964.
From the decision:
The Court finds that Williams has met her burden at this stage and stated a claim for hostile work environment under Title VII and the IHRA. Williams has alleged the basic components of her claim: “the type of discrimination” (on the basis of sex and sexual orientation); “the whom” (other employees); “and the when” (on numerous occasions). Huri v. Off. of the Chief Judge of the Cir. Ct. of Cook Cnty., 804 F.3d 826, 834 (7th Cir. 2015); (see also R. 1 ¶ 20.) Allegations that, on “numerous occasions,” other CTA employees “discussed [Williams’] private parts” and “refused her entry to offices because she was perceived as dirty due to her sexual orientation,” plausibly state a claim of hostile work environment based on sexual harassment. (R. 1 ¶ 20.) While the CTA contends that Williams has not alleged sufficient severity, the Seventh Circuit has held that “it is premature at the pleadings stage to conclude just how abusive [Plaintiff]’s work environment was.” Huri, 804 F.3d at 834 (7th Cir. 2015). Further, contrary to the CTA’s argument, there is a basis for employer liability because Williams alleges that at least some of the harassment occurred after she went through her union’s grievance process and the CTA failed to address her concerns. (R. 1 ¶¶ 20, 22, 28.)
Based on the foregoing, the court denied defendant’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6).