A collector for a financing firm, who was over 40, complained about age-related remarks made by her manager. Nothing was done and the collector was fired, even though she had received satisfactory evaluations. She filed an age-bias charge with the EEOC. The employer tried to get the complaint dismissed with no luck. In agreeing with the Sixth Circuit, the only court of appeals directly to resolve this issue, an Illinois district court found that a hostile work environment claim can be brought under the Age Discrimination in Employment Act (ADEA). Look for this question, whether an age-based hostile environment claim is viable, to be resolved when the Supreme Court rules this spring on Adams v. Florida Power Corp.
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