7th Circuit offers primer on objective severity standards for unlawful harassment

October 2026 employment law letter

Authors:

Cecilia A. Heberling, Axley LLP

A former court reporter for the Wisconsin Circuit Court for Rusk County filed a federal lawsuit against the state director of courts, a judge, and others alleging, among other claims, that she suffered a hostile work environment based on her sex in violation of Title VII of the Civil Rights Act of 1964. The U.S. District Court for the Western District of Wisconsin granted summary judgment (dismissal without a trial) in favor of the defendants. In affirming, the U.S. 7th Circuit Court of Appeals (whose rulings apply to all employers in Wisconsin, Illinois, and Indiana) provided a useful primer on Title VII’s “objective severity” or pervasiveness standard.

What happened?

Shannon Golat worked as a court reporter at the Rusk County Circuit Court from 2017 to 2022. She alleged that she was subjected to sexual harassment because the male judge she worked for made sexist comments to her, including:

That she must be a lesbian because she drove a Subaru;
That she was a “typical woman” who nagged him;
That she was like a “junior high school girl,” and asked if she was going to go back to her office and cry; and
That he had a large penis, could sleep with any woman in the county, and made jokes about a condom factory.

Golat also alleged the judge used a mug in the courtroom that was decorated with male genitalia and had the words “hung jury” printed on it. She also alleged that the judge permitted others to make sexist comments about her, including:

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