Yancick v. Hanna Steel Corp.
2011 U.S. App. LEXIS 15896
| 7th Cir. | 2011Background
- Yancick, a white Hanna Steel employee, alleged a racially hostile environment by coworker Johnson, an African-American, under 42 U.S.C. § 1981.
- The plant workforce was predominantly white and Hispanic; only two African-American employees existed, and Johnson worked the same shift as Yancick for part of his tenure.
- In December 2005, a 940-pound steel coil fell on Yancick, injuring him; he claimed Johnson dropped it intentionally due to race.
- Hanna Steel had a harassment policy directing complaints to HR; Yancick acknowledged the policy in 2005 and was aware of the reporting chain.
- Before the injury, Johnson engaged in boorish and sometimes racially tinged conduct; Yancick reported some incidents to his supervisor Duncan, who largely did not act.
- The district court declined to consider Yancick’s noncompliant summary judgment response due to Local Rule requirements, and then granted summary judgment for Hanna Steel; Yancick appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by not considering the response to summary judgment | Yancick argues the court should have considered his rule-compliant response and exhibits. | Hanna Steel contends strict compliance with local rules justified disregarding the out-of-compliance response. | No abuse; court properly enforced deadlines and Local Rules. |
| Whether the record shows a racially hostile work environment before the 2005 injury | Yancick asserts Johnson’s pre-accident conduct evidences racial hostility aimed at him. | Hanna Steel argues pre-injury conduct was not severe or pervasive and not racially motivated toward Yancick. | Insufficient evidence of a race-based, severe, or pervasive hostile environment pre-accident. |
| Whether Hanna Steel is liable for co-employee harassment | Yancick contends employer liability due to failure to remedy harassment and notice of discrimination. | Hanna Steel argues lack of evidence that harassment was race-based and that notice or supervisory authority was insufficient for liability. | No employer liability; notice and supervisory authority were insufficient and no race-based causation shown. |
Key Cases Cited
- Raymond v. Ameritech Corp., 442 F.3d 600 (7th Cir. 2006) (abuse-of-discretion standard for summary judgment rulings)
- Spears v. City of Indianapolis, 74 F.3d 153 (7th Cir. 1996) (deadline-enlargement discretion; diligence in meeting deadlines)
- Smith v. Ne. Ill. Univ., 388 F.3d 559 (7th Cir. 2004) (hostile environment requires objective and subjective severity)
- Vance v. Ball State Univ., 646 F.3d 461 (7th Cir. 2011) (harassment must have racial character or purpose; overall context)
- Durkin v. City of Chi., 341 F.3d 606 (7th Cir. 2003) (employer liability limitations for harassment cases)
- Montgomery v. Am. Airlines, Inc., 626 F.3d 382 (7th Cir. 2010) (notice and employer liability standards in discrimination claims)
- Parkins v. Civil Constructors of Ill., Inc., 163 F.3d 1027 (7th Cir. 1998) (notice and relief considerations in harassment claims)
- Bohannon v. Pegelow, 652 F.2d 729 (7th Cir. 1981) (relevance of lay opinion on motive in discrimination cases)