On September 1, 2021, the 7th Circuit affirmed an order of summary judgment in favor of an employer, in a Title VII and Illinois Human Rights Act employment discrimination lawsuit, in which the plaintiff, an Egyptian Muslim pharmacist, alleged that: (i) the employer failed to accommodate his need for prayer breaks; (ii) disciplined and later fired him based on his race, religion, and national origin; (iii) retaliated against him for reporting racial and religious discrimination; and (iv) subjected him to a hostile work environment based on his race, religion, and national origin. Mahran v. Advocate Christ Medical Center, et al., No. 19-2911 (7th Cir. Sept. 1, 2021).
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On August 17, 2021, the 7th Circuit affirmed an order of summary judgment for an employer in a reverse race discrimination lawsuit, in which the plaintiff claimed that he fired because he is white. Bless v. Cook County Sheriff's Office, et al., No. 20-2733 (7th Cir. Aug. 17, 2021). The plaintiff, a Cook County Illinois Sheriff's police officer, was fired in connection with an internal review board determination that he had committed misconduct. The plaintiff sued the County, alleging reverse race discrimination and political retaliation against him as a white Republican. The protections of Title VII are not limited to members of historically discriminated-against groups.
On August 4, 2021, the 7th Circuit affirmed the district court's denial of the plaintiff's motions for judgment as a matter of law and for a new trial, in a Title VII retaliation lawsuit tried before a jury in federal court. Brooks v. City of Kankakee, Illinois, No. 20-1395 (7th Cir. Aug. 4, 2021). The plaintiff, an African-American police officer, made three statements complaining that his employer, the City of Kankakee, favored white police officers. The City viewed the statements as false and disparaging. It issued a written reprimand, ordering him to stop making such statements and threatening disciplinary action if he didn't. The written reprimand specifically referenced all three statements. The plaintiff alleged retaliation based on failure to promote and discipline.
On July 20, 2021, the 7th Circuit affirmed an order of summary judgment in favor of an employer on ADEA and Title VII employment discrimination and retaliation claims, in which the plaintiff alleged that the employer failed to re-hire her for various positions in the Chicago Public School System because of her age and race, as well as in retaliation for her prior discrimination complaint. Chatman v. Board of Education of the City of Chicago, No. 20-2882 (7th Cir. July 20, 2021). She alleged violations of Title VII's anti-discrimination and anti-retaliation provisions, as well as a violation of the anti-discrimination provisions of the Age Discrimination in Employment Act ("ADEA"). Title VII makes it unlawful for an employer to fail or refuse to hire any individual with respect to her compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin.
On July 14, 2021, the 7th Circuit affirmed an order of summary judgment in favor of the defendant in a Title VII employment discrimination and retaliation lawsuit, in which the plaintiff alleged that he was disciplined and denied a promotion because of his race and gender as well as in retaliation for opposing unlawful sexual harassment. Logan v. City of Chicago, et al., No. 20-1669 (7th Cir. July 14, 2021). Title VII prohibits an employer from discriminating against any individual with respect to his or her compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin. For a failure-to-promote claim,
On June 16, 2021, the 7th Circuit affirmed an order of summary judgment in favor of a defendant in a Title VII retaliation and sex discrimination lawsuit, in which the plaintiff alleged that the defendant refused to hire her twice, in retaliation for filing an earlier complaint of sex discrimination. Eaton v. J.H. Findorff & Son, Inc., No. 20-1731 (7th Cir. June 16, 2021). The plaintiff had filed a charge of discrimination against the company with the EEOC, alleging that her layoff amounted to unlawful discrimination on the basis of her sex. Subsequently, she filed her federal lawsuit, claiming both sex discrimination and retaliation for previously complaining about sex discrimination. Only the retaliation claim was at issue on appeal. In order to establish a retaliation claim under Title VII, a plaintiff must demonstrate that:
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