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Prompt Response to Complaint Bars Claim for Sexual Harassment
A federal district court for the Northern District of Illinois has held that Eastman Kodak Co.'s prompt response to an employee's complaint of sexual harassment barred her claim under Title VII. Czemske v. Eastman Kodak Co., 2003 WL 21418319 (N.D. Ill. June 16, 2003).
Christine Czemske was employed by Eastman Kodak Co. (Kodak) in several capacities between 1994 and 2000. In 1998, a co-worker superimposed Ms. Czemske's face over two images of nearly nude women in sexually suggestive poses. She did not report the incident at that time. In April 2000, the same co-worker displayed one of the images to two of Ms. Czemske's supervisors, and suggested that the image serve as her business card. Two weeks later, Ms. Czemske showed both images to one of the supervisors, who claimed he only recognized the sexual nature of the images when viewing them both simultaneously. Despite the supervisor's efforts to convince her otherwise, Ms. Czmeske opted to resign. The supervisor called the co-worker, determined that the images violated Kodak's zero tolerance policy, and fired him. Subsequently, Ms. Czemske sued under Title VII, alleging sexual harassment.
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