Labor & Employment Law Daily Wrap Up, DISCRIMINATION—W.D. Wis.: State court system prevails in former court reporter’s workplace discrimination suit, (Nov 6, 2025)

By George Basharis, J.D.

Isolated remarks such as calling her a “typical woman,” suggesting she was a lesbian because she drove a Subaru, and using a “hung jury” mug were insufficiently severe or pervasive to create an abusive work environment, the court determined.

A Wisconsin federal court granted an employer’s motion for summary judgment, rejecting claims of workplace harassment, disability bias, and retaliation by a former Rusk County Circuit Court reporter against the Wisconsin State Court System and several administrators. The court held that the undisputed evidence failed to establish either a hostile work environment or unlawful retaliation and that the accommodations provided for the employee’s medical restrictions were reasonable under federal law. In granting summary judgment, the court found that many of the alleged incidents were unrelated to the employee’s sex or disability and that disciplinary actions were supported by legitimate, nondiscriminatory reasons. The court concluded that the record, even when viewed in the employee’s favor, presented no basis for a trial (Golat v. Wisconsin State Court System, No. 23-cv-719-jdp (W.D. Wis. Nov. 3, 2025)).

The employee worked for the Wisconsin State Court System from 2003 until 2022 and spent her final twelve years serving as the official court reporter for a Rusk County Circuit Court judge. During that period, she claimed that she was subjected to repeated sexist remarks, isolated in the workplace, and denied reasonable accommodations following a work-related elbow injury that limited her ability to type.

Her complaint asserted violations of Title VII and the Rehabilitation Act, along with a claim under the federal civil rights statute that allows individuals to seek relief for constitutional violations by state officials acting under color of law. She alleged that the judge and other court administrators used disciplinary investigations and negative performance findings as pretext for retaliation after she complained about harassment and requested accommodations.

Limited evidence of sex-based hostility. The court first addressed the hostile work environment allegations brought under Title VII and the parallel civil rights claim permitting suits against state officials for constitutional violations. To prevail, the employee needed to show that she was subjected to unwelcome harassment because of her sex, that the conduct was severe or pervasive enough to alter the conditions of employment, and that a basis existed for employer liability.

The court found that much of the alleged mistreatment, including workplace disputes with a judicial assistant, exclusion from office communications, and multiple disciplinary investigations, was not tied to the employee’s sex. Even assuming that certain comments were gender-related, the court concluded that isolated remarks such as calling her a “typical woman,” suggesting she was a lesbian because she drove a Subaru, and using a “hung jury” mug in chambers were insufficiently severe or pervasive to create an abusive work environment.

The court explained that rude or unprofessional behavior, even when laced with occasional gender references, does not meet the threshold for a Title VII hostile environment absent frequent, threatening, or debilitating conduct. The handful of sexist comments over several years, the court said, fell well below that standard.

Reasonable accommodations provided. Turning to the Rehabilitation Act claims, the court found no evidence that the court system failed to accommodate the employee’s elbow injury. The employee argued that her reassignment to transcribe from digital audio recordings instead of live hearings, her relocation to a different office, and a policy requiring use of full sick-leave days for medical appointments were unreasonable.

The court disagreed, holding that the digital recording system and adjusted schedule were reasonable accommodations because they allowed her to perform essential job functions despite medical restrictions on typing. Employers, the court noted, are not obligated to provide an employee’s preferred accommodation, only one that is reasonable.

The record also showed that court administrators allowed reduced schedules, medical leave, and transcript assistance from other reporters when appropriate. A supervisor’s refusal to assign floating reporters solely to avoid digital transcription did not constitute denial of accommodation. According to the court, insisting that an employee complete assigned work consistent with her medical limits does not violate the Rehabilitation Act.

Retaliation claims lack causal link. The employee further alleged that she was disciplined and ultimately lost her job in retaliation for reporting harassment and requesting accommodations. The court recognized her complaints as protected activity but held that she failed to establish a causal connection between that activity and any materially adverse employment action.

The court distinguished between minor workplace disagreements and materially adverse actions that would dissuade a reasonable worker from reporting discrimination. Investigations, threatened discipline, and office moves did not meet that standard. The court identified only two events that qualified as adverse actions: a one-week suspension without pay in March 2022 and the loss of her position following her judge’s retirement later that year.

The suspension stemmed from an investigation into a missing vacuum cleaner intended for another office. Although the employee denied wrongdoing, the court credited the employer’s finding that she mishandled court property and provided inconsistent information during the inquiry. Because the disciplinary action was based on an honest belief, even if arguably mistaken, it could not serve as evidence of pretext.

The court also rejected the argument that her non-rehiring after the judge’s retirement was retaliatory. While new judges typically retain their predecessor’s reporters, the successor declined to reappoint her after reviewing a personnel file that included prior reprimands. The district court administrator shared that file with the successor, and the court found no evidence of retaliatory motive in doing so.

No evidence of pretext or continuing scheme. In opposing summary judgment, the employee relied on notes from 2019 discussions among judicial administrators indicating frustration with her medical leave and workplace conflicts. She characterized those discussions as the beginning of a scheme to terminate her for complaining of harassment and seeking disability leave.

The court found this theory unsupported, observing that the discussions occurred nearly three years before her suspension and job loss and reflected ordinary management deliberations rather than retaliation. Even if some supervisors had questioned the legitimacy of her injury, the court said, temporal distance and intervening events undermined any inference of causation.

The court emphasized that speculation and conjecture cannot substitute for evidence of pretext. The defendants articulated consistent, legitimate reasons for each disciplinary action, and the plaintiff presented no proof that those explanations were dishonest or that similarly situated employees were treated differently.

The case is No. 23-cv-719-jdp.

Attorneys: Adam Almen (Hellmuth & Johnson) for Shannon Golat. Adam Almen (Hellmuth & Johnson) for Shannon Golat. Katherine Cuccia Polich, U.S. Department of Justice, for Wisconsin State Court System, Christopher Channing, Caitlin Fredrick, Melissa Bohse and Steven Anderson.

Companies: Wisconsin State Court System

Cases: Discrimination SexDiscrimination DisabilityDiscrimination SexualHarassment Discharge Retaliation WisconsinNews