An Illinois federal district court granted summary judgment to Community First Healthcare of Illinois, Inc. and its president on a claim of racial discrimination under 42 U.S.C. § 1981 brought by an Indian director of materials who alleged the CEO, his supervisor, made ethnicity-based comments, finding that the alleged harassment was not objectively hostile, severe, or pervasive enough to be actionable, and there was no evidence the CEO’s conduct was motivated by racial animus as he behaved similarly toward employees of all races.
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