Gilliam v. Berkeley Contract Packaging, LLC (IL), 3:12-cv-01174

Gilliam worked at Berkeley Contract Packaging's Edwardsville, Illinois facility on the Line and as a QC cross-trainee from March to June 2011.
Gilliam reported to Shirley Reed (QC Supervisor); Ken Lewis was QC Manager; Belem Garcia supervised on the Line in June 2011.
On June 16, 2011 Gilliam alleges a shoulder/back touch by Lockhart and comments about her appearance and body.
On June 21, 2011 Gilliam was told not to return to work; Berkeley claims she was insubordinate and refused Line duties after speaking with Garcia.
Gilliam filed a Charge with IDHR/EEOC in 2011; IDHR found substantial evidence and EEOC issued suit rights; Gilliam later amended her complaint adding Title VII claims.
Berkeley moved for summary judgment on Gilliam’s IHRA and Title VII claims; the court granted summary judgment in Berkeley’s favor on all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Quid pro quo liability proof	Gilliam argues reversal of advances was linked to termination.	Berkeley contends no evidence that rejection caused the termination.	Gilliam cannot prove a causal link; no tangible employment action shown.
Hostile work environment standard	Gilliam contends Lockhart's conduct was pervasive and offensive.	Berkeley argues conduct was not severe or pervasive enough to be actionable.	Evidence does not meet objective severity/pervasiveness standard.
Employer liability under Title VII/IHRA	Gilliam asserts liability based on supervisor conduct and hostile environment.	Berkeley argues lack of qualifying conduct or connection to termination.	Summary judgment for Berkeley on all counts; no basis for employer liability found.

Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (Supreme Court 1998) (distinguishes quid pro quo and hostile environment frameworks)
Patt v. Family Health Sys., Inc., 280 F.3d 749 (7th Cir. 2002) (insufficient severity for hostile environment claim)
Hilt-Dyson v. City of Chicago, 282 F.3d 456 (7th Cir. 2002) (brief touching not actionable harassment)
Pryor v. Seyfarth, Shaw, Fairweather & Geraldson, 212 F.3d 976 (7th Cir. 2000) (objectively offensive conduct required for harassment claims)
Adusumilli v. City of Chicago, 164 F.3d 353 (7th Cir. 1998) (teasing and isolated incidents insufficient for Title VII claims)
Weiss v. Coca-Cola Bottling Co., 990 F.2d 333 (7th Cir. 1993) (isolated incidents not actionable harassment)
Saxton v. AT&T Co., 10 F.3d 526 (7th Cir. 1993) (jazz club/locker-room type conduct not actionable)
Howard v. Sheahan, 546 F. Supp.2d 566 (N.D. Ill. 2008) (general compliments and leering not actionable)
Harris v. Franklin-Williamson Human Servs., Inc., 97 F. Supp.2d 892 (S.D. Ill. 2000) (broad statements over time not necessarily actionable)
Lindblom v. Challenger Day Program, Ltd., 37 F. Supp.2d 1109 (N.D. Ill. 1999) (staring and touching, insufficient for Title VII)