Title VII (Title VII of the Civil Rights Act of 1964, as amended)

No Adverse Employment Action, No Viable Employment Discrimination Claim

The Seventh Circuit Court of Appeals recently affirmed the district court's grant of summary judgment in a case in which the plaintiff alleged that the employer terminated her employment on account of age discrimination, reverse race discrimination, sex discrimination, and retaliation.  Andrews v. CBOCS West, No. 12-3399 (7th Cir.), February 14, 2014.  The plaintiff filed a lawsuit against her employer in which she brought claims under Title VII of the Civil Rights Act of 1964, as amended, the Age Discrimination In Employment Act, and Section 1981 of the Civil Rights Act of 1866.  The plaintiff was subjected to daily, derogatory age-based remarks made by her supervisor.  However, the Seventh Circuit found that the plaintiff had voluntarily resigned from employment and, therefore, suffered no materially adverse employment action. 

Title VII of No Avail to Job Applicant Promised Phony Job in Exchange for Sexual Favors

The Seventh Circuit Court of Appeals recently held that a job applicant who was promised a phony job by the job interviewer in exchange for sexual favors cannot maintain a viable sexual harassment claim under Title VII of the Civil Rights Act of 1964, as amended.  Wilson v. Cook County, No. 13-1464 (7th Cir.), February 10, 2014.  The Seventh Circuit reasoned that neither the phony job nor any employment relationship ever existed and, therefore, the plaintiff could not establish a failure to hire claim or a sexual harassment claim. 

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