Case Explained: SHANNON GOLAT v. HONORABLE AUDREY K. SKWIERAWSKI, et al

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-04 The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants on Shannon Golat’s claims under Title VII, the Rehabilitation Act, and 42 U.S.C. § 1983. The court held that Golat failed to establish a hostile work environment because the alleged sexist comments and conduct by her supervisor, Judge Anderson, were not sufficiently severe or pervasive to alter the conditions of employment, characterizing them as sporadic vulgar banter rather than actionable harassment. Regarding her disability accommodation claims under the Rehabilitation Act, the court found no violation because the employer’s requirement that she use full-day sick leave for medical appointments and its assignment of asynchronous transcription work via a digital audio recording system constituted reasonable accommodations that allowed her to perform essential job functions. Finally, the court rejected her retaliation claims, determining that she could not prove but-for causation between her protected activities and the adverse employment actions; specifically, the one-week suspension was supported by non-retaliatory reasons regarding her handling of a missing vacuum, and the decision not to rehire her after her judge’s retirement was based on her misconduct record and recommendations from other judges that were not proximately caused by biased motives. The judgment of the district court remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.