Littler Lightbulb: May Appellate Roundup

This Littler Lightbulb highlights some of the more significant employment law developments in the federal courts of appeal in the last month.

• Seventh Circuit Finds EEOC Failed to Prove Racial Harassment in Multi-Employee Case

In EEOC v. Village at Hamilton Pointe LLC, __ F.4th __, 2024 U.S. App. LEXIS 11350 (7^th Cir. 2024), the Seventh Circuit upheld summary judgment for the employer in a case brought by the EEOC claiming Black employees at an assisted living facility were subjected to harassment because of their race in violation of Title VII. Citing prior Seventh Circuit precedent the appellate court stated that to prevail on a racial harassment claim "[a] plaintiff must show that the alleged harassment was so severe or pervasive that it altered the conditions of his employment.... The subjective beliefs of an employee are not sufficient alone to meet this standard."