The problems for Illinois employers when supervisors harass subordinates just got more complicated. On April 16, 2009, in Sangamon County Sheriff’s Department v. Illinois Human Rights Commission, ___ Ill. 2d ___ (Ill. April 16, 2009) (link: www.state.il.us/court/opinions/supremecourt/2009/april/105517.pdf), the Illinois Supreme Court adopted a new standard that imposed strict liability on employers in cases under the Illinois Human Rights Act involving sexual harassment by supervisors.