7th Circuit Affirms Summary Judgment for Employer in Reverse Discrimination Lawsuit

On September 23, 2015, the 7th Circuit affirmed summary judgment in favor of the defendant in a reverse discrimination case, in which a Caucasian professor alleged that a university failed to hire him for an open tenure-track assistant professor position because of his race.  Rahn v. Board of Trustees of Northern Illinois University, No. 14-2402 (7th Cir., 9-23-2015).  He alleged that the dean of the college had stated that he would not hire a white man into the department if qualified minority candidates were available.  He also claimed that the metric used by the search committee to rank the candidates for the position was designed to eliminate him from consideration.  After the professor did not make the final cut of candidates, the dean selected a non-Caucasian candidate for the position from the final group.

The alleged statement by the dean did not constitute direct evidence of discrimination.  The dean was not a member of the search committee, which had eliminated the professor based on its legitimate metric evaluation, before the final group of candidates was submitted to the dean.  The professor did not present any evidence to contradict the university's position, that the successful candidate was more qualified for the position, and that he was hired for this non-discriminatory reason unrelated to race.