Sangamon County Sheriff's Department v. Illinois Human Rights Commission

I agree with the majority that the Commission properly considered acts by Yanor which occurred prior to sending the forged letter. I also support its conclusion that the Commission’s finding regarding the existence of a hostile work environment was not against the manifest weight of the evidence. Where I part company with my colleagues is on the question of whether the Sheriff’s Department should be held vicariously hable for Yanor’s misconduct.

Contrary to the majority, I believe that the appellate court was correct when it concluded that vicarious liability cannot be imposed here because,…