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Impact of 'Second Hand Harassment' Does Not Amount to Objectively Hostile Work Environment
In affirming a district court's ruling rejecting hostile work environment and retaliation claims brought by three black and one Latina employee against Northeastern Illinois University (“Northeastern”), the Seventh Circuit has found that when harassment is “directed at someone other than the plaintiff, the 'impact of [such] second hand harassment is obviously not as great as the impact of harassment directed at the plaintiff.'” Smith v. Northeastern Illinois University, 2004 WL 2475104 (7th Cir. Nov. 4).
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