Northington v. H & M International

On March 21, 2013, the Seventh Circuit ruled in Northington v. H & M International, No. 12-1233, a Title VII case alleging that plaintiff was fired in retaliation for making a complaint that co-workers harassed plaintiff.

The Seventh Circuit held that the District Court did not err in granting employer’s motion for summary judgment.

The Seventh Circuit noted that the employee did not state at the time of the complaint that co-workers harassment of the employee was based on any protected classification. Furthermore, the record established that the motivation for the harassment was based only on personal conflict between the plaintiff and her co-workers. As such, plaintiff failed to show that she had engaged in protected activity to support retaliation claim.