Justia U.S. 7th Circuit Court of Appeals Opinion Summaries

A special education teacher with a long and distinguished career in an Illinois public school district was involuntarily transferred from one elementary school to another at age 52. After the transfer, she alleged that she was subjected to a hostile work environment at her new school. She claimed that she was assigned a disproportionate number of challenging students, unfairly criticized, denied adequate classroom support, and intimidated by an administrator. She believed these actions were motivated by her age, although she acknowledged that no one made any explicit age-related remarks.After she filed a complaint under the Age Discrimination in Employment Act (ADEA), the United States District Court for the Central District of Illinois granted summary judgment in favor of the school district. The district court found that she had not produced evidence from which a reasonable juror could conclude that the alleged harassment was either objectively hostile or based on her age.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the grant of summary judgment de novo. The appellate court assumed, without definitively deciding, that hostile work environment claims are cognizable under the ADEA. However, it held that the teacher failed to present sufficient evidence that any of the conduct she experienced was motivated by age-based animus. The court found her assertions to be speculative and unsupported by direct or circumstantial evidence. As a result, the Seventh Circuit affirmed the district court’s judgment, holding that there was no reasonable basis to infer age-based workplace harassment under the ADEA. View "Blumenshine v. Bloomington School District No. 87" on Justia Law

Four individuals who worked as drivers for a ride-sharing company alleged that the company misclassified them as independent contractors rather than employees, resulting in violations of federal and Illinois wage laws. The drivers claimed they were denied minimum wage, overtime pay, and reimbursement for business expenses. Each driver had entered into agreements with the company that included arbitration provisions, but these agreements also allowed drivers to opt out of arbitration within a specified period. One driver, Ken Zurek, opted out of the arbitration provision in a later agreement after not opting out of an earlier one.Before joining the federal lawsuit, Zurek had filed a separate case in Illinois state court, where the company sought to compel arbitration based on the earlier agreement. The state court found that Zurek’s opt-out from the later agreement meant he was not bound to arbitrate claims arising during the period covered by that agreement, even if he had not opted out of the earlier one. The state court did not decide whether Zurek had actually agreed to the earlier arbitration provision, finding it unnecessary for the resolution of the case. The parties later settled the state court case.In the United States District Court for the Northern District of Illinois, the company again moved to compel arbitration for all four drivers. The district court granted the motion for three drivers but denied it for Zurek, holding that the state court’s decision precluded relitigation of whether Zurek was bound by the earlier arbitration agreement. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s denial of the motion to compel arbitration as to Zurek, holding that issue preclusion applied because the state court had already decided the relevant issue. View "Agha v. Uber Technologies, Inc." on Justia Law

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal.After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

A registered nurse, who identified as a dark-skinned Salvadoran woman, was employed at an acute care hospital. After a night in which she took a prescribed opioid for shingles, she reported to work without notifying her supervisor of her medication use. On that day, two incidents occurred in which controlled opioids were improperly removed from the hospital’s secure medication dispensing system. Several coworkers observed that the nurse appeared disoriented, drowsy, and exhibited slurred speech. Following these observations and the missing medication, supervisors required her to undergo a fitness for duty exam and drug test, which was positive for opiates but later deemed explained by her prescription. The hospital conducted an internal investigation, reviewed security logs, and ultimately terminated her employment for suspected drug diversion, policy violations, and unsafe patient care.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the hospital on all claims. The nurse had alleged discrimination and retaliation based on color and national origin under Title VII, disability discrimination and failure to accommodate under the ADA, interference and retaliation under the FMLA, and violations of the Illinois Human Rights Act. The district court found that no reasonable factfinder could conclude the hospital’s actions were unlawful.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment. The appellate court held that the nurse failed to establish a prima facie case of discrimination or retaliation under Title VII, as her conduct and observed behavior distinguished her from other employees. The court also found insufficient evidence to support her ADA, FMLA, and IHRA claims, concluding that the hospital’s actions were not shown to be motivated by unlawful animus or to have violated any statutory rights. The court affirmed the judgment in favor of the hospital on all claims. View "Lohmeier v Gottlieb Memorial Hospital" on Justia Law

Stella Paterakos, a white woman, worked as an Assistant Community Living Specialist for the City of Chicago. In 2020, after Crystal Warren, a black woman, became her supervisor, Paterakos was disciplined three times, resulting in suspensions of one, three, and five days. The cited reasons for discipline included violations of office policies, work assignments, and issues related to her use of Family and Medical Leave Act (FMLA) leave. Paterakos admitted to much of the conduct underlying the suspensions but alleged she was singled out for harsh treatment due to her race. She also claimed that her third suspension interfered with or retaliated against her for taking FMLA leave. Additionally, she was temporarily assigned to a different office, which she argued was racially motivated.After her third suspension, Paterakos filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging violations of Title VII of the Civil Rights Act, the Equal Protection Clause, the FMLA, and the Age Discrimination in Employment Act. The defendants moved for summary judgment. The district court granted summary judgment on all claims, finding no reasonable jury could conclude that the suspensions or the temporary assignment were motivated by race, age, or constituted unlawful FMLA interference or retaliation. Paterakos appealed, dropping her age discrimination claim but challenging the summary judgment on her Title VII, Equal Protection, and FMLA claims.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed the district court’s judgment, holding that no reasonable jury could find that the suspensions or assignment were based on race rather than documented performance issues. For the FMLA claims, the court held that the defendants’ honest belief that Paterakos was abusing her FMLA leave defeated her interference and retaliation claims. View "Paterakos v City of Chicago" on Justia Law

Alex Kedas worked for the Illinois Department of Transportation (IDOT) for over thirty years, primarily as a senior resident engineer. In 2016, Kedas complained to management and legal counsel that a female colleague was receiving better job assignments due to gender favoritism. After his complaint, Kedas received a counseling memorandum, a negative performance evaluation, and was denied a merit-based bonus. In subsequent years, he was assigned less significant projects and faced additional disciplinary actions. Kedas believed these actions were retaliatory and ultimately resigned in 2021, claiming constructive discharge due to an intolerable work environment.Kedas filed a lawsuit in the United States District Court for the Central District of Illinois, alleging retaliation under Title VII of the Civil Rights Act of 1964. The district court granted partial summary judgment for IDOT, finding that only certain actions—specifically, the counseling memorandum, the negative performance review, the denial of a bonus, and the 2018 job assignments—could be considered materially adverse employment actions. However, the court then found no sufficient evidence of a causal link between Kedas’s protected activity and his 2018 job assignments or constructive discharge. The remaining claims proceeded to trial, where the jury found IDOT had retaliated by issuing the counseling memorandum but awarded no damages.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment rulings de novo. The appellate court held that Kedas failed to present sufficient evidence to support claims of constructive discharge or a causal connection between his protected activity and the 2018 job assignments. The Seventh Circuit affirmed the district court’s judgment, concluding that no reasonable jury could find in Kedas’s favor on these issues. View "Kedas v Illinois Department of Transportation" on Justia Law

A customer service analyst at a large corporation alleged that her supervisors created a hostile work environment characterized by inappropriate behavior and a culture of “machismo.” She reported these concerns to human resources, including claims of increased workload without overtime approval and specific instances of inappropriate conduct. The company investigated, found low morale but no evidence of discrimination or harassment, and paid her owed overtime. After her complaints, the analyst received escalating warnings about her work performance, culminating in the lowest possible rating on her annual review. She was then given the choice between a performance improvement plan or resignation. Following an emotional reaction to this meeting, the company withdrew the improvement plan option and terminated her employment.She filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging gender discrimination and retaliation under Title VII, and age discrimination and retaliation under the Age Discrimination in Employment Act. The district court granted summary judgment in favor of the employer, finding insufficient evidence to support her claims.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering whether a reasonable factfinder could conclude that her gender, age, or protected activity caused her termination. The court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, did not present evidence that her age was the “but for” cause of her termination, and could not establish a causal link between her complaints and adverse employment actions. The court found no evidence of pretext or retaliation and concluded that the record did not support her allegations. The Seventh Circuit affirmed the district court’s grant of summary judgment to the employer. View "Ontiveros v. Exxon Mobil Corporation" on Justia Law

Monica Richards, a long-time employee in her early fifties, applied for a promotion at Eli Lilly & Company after serving as an interim District Sales Manager. The promotion was instead awarded to a younger, less experienced candidate. Richards filed suit in federal court, alleging age discrimination under the Age Discrimination in Employment Act (ADEA) and Massachusetts law. She sought to proceed collectively on behalf of all Eli Lilly employees aged 40 or older who were denied promotions since February 2022, claiming a companywide bias favoring “Early Career Professionals” over older employees.In the United States District Court for the Southern District of Indiana, Richards moved for conditional certification of a collective action and requested that notice be sent to potential opt-in plaintiffs. The parties disputed the appropriate standard for issuing such notice. The district court applied the Lusardi “modest factual showing” standard, declined to consider the employer’s opposing evidence, and granted conditional certification, agreeing to send notice. Recognizing uncertainty in the law, the district court certified the question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the case to clarify the standard for issuing notice in Fair Labor Standards Act (FLSA) and ADEA collective actions. The court held that, before notice may issue, plaintiffs must present evidence raising a material factual dispute as to whether the proposed collective is similarly situated. Both parties’ evidence must be considered, and the district court retains discretion to manage the process, including authorizing limited discovery or narrowing the scope of notice. The court rejected both the lenient Lusardi standard and heightened standards requiring proof by a preponderance of the evidence or a strong likelihood of similarity. The Seventh Circuit vacated the district court’s order and remanded for further proceedings under the clarified standard. View "Richards v. Eli Lilly & Company" on Justia Law

A high school in Indiana implemented a policy requiring teachers to address students by the first names listed in the school’s database, which, for transgender students, reflected their chosen names. A teacher objected to this policy on religious grounds, believing that using names inconsistent with students’ biological sex would violate his faith. The school initially accommodated him by allowing him to address all students by their last names only. After a year, complaints from students, parents, and staff led the school to rescind this accommodation, requiring the teacher to use students’ first names or face termination. The teacher resigned and later attempted to rescind his resignation, but the school treated it as final.The teacher sued the school corporation in the United States District Court for the Southern District of Indiana, alleging violations of Title VII for failure to accommodate his religion and for retaliation. The district court denied the teacher’s motion for summary judgment on the accommodation claim, finding a factual dispute about the sincerity of his religious beliefs. The court granted summary judgment to the school on both claims, concluding that accommodating the teacher imposed more than a de minimis cost due to student and staff complaints and potential Title IX liability. The court also found no evidence of pretext in the school’s stated reasons for its actions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case in light of the Supreme Court’s decision in Groff v. DeJoy, which clarified that an employer must show a “substantial” burden to deny a religious accommodation under Title VII. The Seventh Circuit held that material factual disputes remained regarding whether the accommodation caused an undue hardship on the school’s mission or exposed it to legal liability. The court affirmed the denial of summary judgment on the sincerity issue, affirmed the decision not to revisit the retaliation claim, reversed the grant of summary judgment to the school on the accommodation claim, and remanded for further proceedings. View "Kluge v. Brownsburg Community School Corporation" on Justia Law