7th Circuit Affirms Summary Judgment for Employer in Title VII Race Discrimination Lawsuit

On August 5, 2020, the 7th Circuit affirmed an order of summary judgment in favor of a defendant-employer in a Title VII race discrimination lawsuit in which the plaintiff alleged that her teaching contract was not renewed on account of her race.  Allen-Noll v. Madison Area Technical College, et al., No. 19-2639 (7th Cir. Aug. 5, 2020).  When her teaching contract with the MATC was not renewed, the plaintiff sued her former employer, alleging racial discrimination and harassment.  The primary adverse employment action that the plaintiff claimed to have suffered was the college's decision to not renew her contract.  However, she offered no evidence that this was because of her race, or in retaliation for her internal complaint of discrimination.  Her allegations of racial discrimination and retaliation were unsupported by any facts.

The record demonstrated that the college had legitimate, performance-based reasons not to renew her contract.  The record contained no evidence that race played any role in the college's decision to not renew her contract.  In addition, she failed to identify a similarly-situated employee outside of her protected class who was treated more favorably than her.  She also failed to establish that the college's legitimate, non-discriminatory reasons for not renewing her contract were pretextual.  The plaintiff simply failed to produce evidence to establish the elements of her Title VII employment discrimination claim.