Flanagan v. Office of the Chief Judge of the Circuit Court of Cook County, No. 16-1927 (7th Cir. 2018)Annotate this Case
Flanagan sued under Title VII, 42 U.S.C. 20003, alleging that two coworkers threatened her life because she previously successfully sued their shared employer, the Cook County Adult Probation Department, for discrimination and retaliation. Flanagan claims that her colleague overheard human-resources director Vaughan, tell deputy chief, Loizon, “to figure out a way to get [Flanagan] alone and away from her partner.” On March 13, 2008, Loizon radioed for Flanagan to join him and another supervisor at an Adult Probation facility to question a probationer regarding a potential tip. After the questioning, Loizon and the probationer left through the back door. The other supervisor then locked the front door and escorted Flanagan toward the back. While near the back door, Flanagan overheard Loizon say, “Do it to her when she gets out the door.” Nothing further happened. After Flanagan filed another EEOC charge, Loizon approached her in the office parking lot, exchanged words with her, and warned, "I could hit you and nobody would give a fuck.” The district court granted the defendants summary judgment. The Seventh Circuit affirmed, reasoning that the threat to Flanagan was too oblique for a jury to conclude that she was subjected to severe or pervasive harassment.