Richards v. U.S. Steel, No. 16-2436 (7th Cir. 2017)Annotate this Case
Richards was hired in 1995. While working with Byrd, Richards had several negative experiences with her supervisors. In 2011, Richards filed a discrimination complaint. Feeling that human resources had not adequately addressed her concerns, Richards called a U.S. Steel employee hotline to report incidents involving Byrd. Richards met with human resources personnel. When asked about a particular incident, she became upset and started crying. Human Resources told Richards she was too emotional and should see a psychiatrist. Several months later, Richards failed to show up or call off for an overtime shift that she was scheduled to work. Richards was suspended. After a hearing, her suspension was converted to a discharge. After arbitration, the discharge was overturned. Richards was evaluated by a psychologist, who diagnosed Richards with Post‐traumatic Stress Disorder and Dysthymic Disorder, likely as a "result of [the] traumatic experiences [Richards] encountered while on the job.” The Seventh Circuit affirmed the summary judgment rejection of her Illinois state‐law claim for intentional infliction of emotional distress. U.S. Steel can be held responsible for only some of the factual allegations that Richard relied on; on those facts, U.S. Steel did not engage in “extreme and outrageous” behavior under Illinois common law.