Overly v. KeyBank Nat'l Ass'n, No. 10-2705 (7th Cir. 2011)Annotate this Case
Plaintiff, a financial advisor, sued her employer for allegedly discriminating based on her gender and retaliating against her because of her complaints of gender discrimination in violation of Title VII of the Civil Rights Act of 1964. The district court granted summary judgment in favor of the employer. The Seventh Circuit affirmed. There was no evidence that a realignment of territories or disciplinary action against plaintiff were based on her gender. While both inappropriate and condescending, a supervisor referring to plaintiff as "cutie" 5 to 10 times over the course of two months was not sufficiently severe or pervasive to create a hostile work environment by itself, especially since it is undisputed that he stopped when asked. Plaintiff did not prove constructive discharge. The supervisor's patently offensive response to her resignation, "good riddance bitch," was not direct evidence of gender discrimination.