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

Two healthcare workers, Megan Passarella and Sandra Dottenwhy, employed by Aspirus Health in Wisconsin, sought religious exemptions from the company's COVID-19 vaccination mandate. Passarella cited her Christian belief that her body is a temple of the Holy Spirit and expressed concerns about the vaccine's safety. Dottenwhy also referenced her Christian faith, stating that her body is a temple and expressing distrust in the vaccine's development and long-term effects. Both were denied exemptions and subsequently terminated.The United States District Court for the Western District of Wisconsin dismissed their Title VII claims, ruling that their objections were based on medical judgment rather than religious conviction. The court found that the plaintiffs did not articulate any religious belief that would prevent them from taking the vaccine if they believed it was safe.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that an employee's request for accommodation is based on religion if it is plausibly connected to their religious beliefs or practices, even if it also includes non-religious reasons. The court emphasized that Title VII's definition of religion is broad and includes all aspects of religious observance and practice. The court found that both Passarella's and Dottenwhy's exemption requests were at least partially based on their religious beliefs, making them sufficient to survive a motion to dismiss. The case was remanded for further proceedings to determine the sincerity of the plaintiffs' beliefs and whether Aspirus could reasonably accommodate them without undue hardship. View "Dottenwhy v. Aspirus, Inc." on Justia Law

Paula Emerson, a former Cook County Corrections Officer, was terminated in 2019 after being on disability leave since 2012 due to anxiety, depression, and PTSD. Emerson claimed her termination was in retaliation for filing a workers' compensation claim in 2014 and a Title VII lawsuit against Cook County and its employees, which she lost. She alleged that the same attorneys represented the County in both her workers' compensation proceedings and the Title VII case, and discussed her cases with those responsible for her termination.The United States District Court for the Northern District of Illinois dismissed Emerson's initial complaint for failure to state a claim, allowing her to amend it. Emerson's amended complaint was also dismissed with prejudice for failing to cure deficiencies. The court found that filing a workers' compensation claim was not a protected activity under the ADA and that Emerson did not adequately allege that her workers' compensation claim caused her termination. Emerson's request for limited discovery was denied due to lack of specific allegations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The appellate court held that Emerson's complaint did not plausibly allege that her workers' compensation claim caused her termination, noting the five-year gap between the claim and her firing. The court also upheld the denial of Emerson's discovery request, deeming it speculative, and found no abuse of discretion in denying her Rule 59(e) motion for reconsideration, as she presented no new evidence or manifest error of law or fact. The judgment of the district court was affirmed. View "Emerson v. Dart" on Justia Law

Stanford Clacks, an African American truck driver, was employed by Kwik Trip, Inc. and experienced racial harassment from fellow employees. During his training, Clacks was harassed by two trainers, Tom Roerkohl and Brett Nechkash, who used racial epithets and made derogatory remarks. Clacks reported these incidents to his supervisor, Sean Clements, but did not initially specify the racial nature of the harassment. After completing his training, Clacks continued to face sporadic racial harassment, including receiving a racially charged note from Nechkash. Clacks went on voluntary pandemic leave in March 2020 and later reported the harassment to Kwik Trip’s Human Resources department, prompting an investigation that led to the termination of the offending employees. Kwik Trip offered Clacks his job back or a severance package, both of which he declined.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of Kwik Trip on all claims. The court applied the sham-affidavit rule to exclude parts of an affidavit Clacks submitted in opposition to summary judgment, finding it contradicted his earlier deposition testimony. The court found that Clacks did not present sufficient evidence to support his claims of a hostile work environment and retaliation.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 properly applied the sham-affidavit rule and that Clacks did not provide sufficient evidence to support his claims. Specifically, the court found that Kwik Trip took reasonable steps to address the harassment once it was reported and that Clacks did not suffer an adverse employment action as he was offered his job back. The court concluded that no reasonable jury could find Kwik Trip liable for a hostile work environment or retaliation. View "Clacks v. Kwik Trip, Incorporated" on Justia Law

In early 2018, employees represented by the International Union of Operating Engineers, Local 150, went on strike at two quarries operated by RiverStone Group, Inc. During the strike, RiverStone disciplined and discharged a union member, required another to sign a hiring list to return to work, unilaterally changed a company policy, and removed picket signs. Local 150 filed charges with the National Labor Relations Board (NLRB), alleging these actions were unfair labor practices.An administrative law judge (ALJ) ruled that RiverStone violated the National Labor Relations Act (NLRA) as charged. RiverStone appealed, and the NLRB affirmed the ALJ’s decision in part. The NLRB found that RiverStone violated the NLRA by denying a union steward’s presence at an investigatory interview, requiring a union member to sign a preferential hiring list, removing picket signs, and unilaterally changing the punch-in policy. However, the NLRB disagreed with the ALJ regarding the discipline and discharge of the union member, concluding that RiverStone acted consistently with its progressive discipline policy.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the NLRB’s findings, stating that substantial evidence supported the Board’s conclusions. The court agreed that RiverStone violated the NLRA by denying the union steward’s presence, requiring the signing of the hiring list, removing picket signs, and unilaterally changing the punch-in policy. However, the court also upheld the NLRB’s decision that RiverStone did not unlawfully discipline and discharge the union member, as the company followed its disciplinary policy. The court denied both RiverStone and Local 150’s petitions for review and granted the NLRB’s cross-application for enforcement. Additionally, the court denied Local 150’s motion for sanctions against the NLRB. View "International Union of Operating Engineers, Local 150 v. National Labor Relations Board" on Justia Law

In early 2018, employees represented by the International Union of Operating Engineers, Local 150, went on strike at two quarries operated by RiverStone Group, Inc. During the strike, RiverStone disciplined and discharged a union member, required another union member to sign a hiring list to return to work, unilaterally changed a company policy, and removed picket signs. Local 150 filed charges with the National Labor Relations Board (NLRB), alleging these actions were unfair labor practices in violation of the National Labor Relations Act.An administrative law judge (ALJ) ruled that RiverStone violated the Act as charged. RiverStone appealed to the NLRB, which affirmed the ALJ’s decision in part. The NLRB found that RiverStone violated the Act by denying a union steward’s presence at an investigatory interview, requiring a union member to sign a preferential hiring list, removing a picket sign, and unilaterally changing the punch-in policy. However, the NLRB disagreed with the ALJ’s finding that RiverStone unlawfully disciplined and discharged the union member, concluding that RiverStone acted consistently with its progressive discipline policy.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the NLRB’s findings, concluding that substantial evidence supported the Board’s order. The court denied the petitions for review from both Local 150 and RiverStone and granted the NLRB’s cross-application for enforcement. The court found that RiverStone violated the Act by denying the union steward’s presence, requiring the signing of a preferential hiring list, removing a picket sign, and unilaterally changing the punch-in policy. However, the court agreed with the NLRB that RiverStone did not unlawfully discipline and discharge the union member. The court also denied Local 150’s motion for sanctions against the NLRB. View "Grove v. National Labor Relations Board" on Justia Law

In early 2018, employees represented by the International Union of Operating Engineers, Local 150, went on strike at two quarries operated by RiverStone Group, Inc. During the strike, RiverStone disciplined and discharged a union member, required another union member to sign a hiring list to return to work, unilaterally changed a company policy, and removed picket signs. Local 150 filed charges with the National Labor Relations Board (NLRB), alleging these actions were unfair labor practices in violation of the National Labor Relations Act.An administrative law judge (ALJ) ruled that RiverStone violated the Act as charged. RiverStone appealed to the NLRB, which affirmed the ALJ’s decision in part. The NLRB found that RiverStone violated the Act by denying a union steward's presence at an investigatory interview, requiring a union member to sign a preferential hiring list, removing a picket sign, and unilaterally changing the punch-in policy. However, the NLRB disagreed with the ALJ regarding the discipline and discharge of the union member, concluding that RiverStone acted consistently with its progressive discipline policy and would have disciplined the employee regardless of his union activity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the NLRB’s findings, concluding that substantial evidence supported the Board’s order. The court denied the petitions for review from both Local 150 and RiverStone and granted the NLRB’s cross-application for enforcement. The court also denied Local 150’s motion for sanctions against the NLRB and its counsel, finding that the Board’s waiver argument had a plausible legal and factual basis. View "National Labor Relations Board v. International Union of Operating Engineers, Local 150" on Justia Law

Jebari Craig, a black employee, worked for Wrought Washer Manufacturing, Inc. from 2010 until his termination in April 2019. Craig, who became the union president in 2018, filed a racial discrimination grievance against Wrought. He alleged that his termination was in retaliation for this grievance. The incident leading to his termination involved a disagreement with a supervisor and subsequent use of his cell phone on the shop floor, which violated company policy. Craig was suspended and later offered a "Last Chance Agreement" to return to work, which he refused to sign, leading to his termination.The United States District Court for the Eastern District of Wisconsin granted summary judgment to Wrought on Craig's claim that his termination was retaliatory. The court found that Craig had not established a prima facie case of retaliation for his written warning and allowed his claim regarding his suspension to proceed. However, it granted summary judgment on the termination claim, crediting Wrought's explanation that the "Last Chance Agreement" did not require Craig to relinquish his discrimination claims, contrary to Craig's later assertions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Schaefer, Wrought's plant manager, was confused during his deposition about the terms of the "Last Chance Agreement" and the severance agreement. The court found that Craig's declaration, which contradicted his earlier statements, did not create a genuine issue of material fact. The court concluded that no reasonable litigant would have withheld the information Craig later provided, supporting the district court's decision to grant summary judgment to Wrought. View "Craig v. Wrought Washer Manufacturing, Inc." on Justia Law

Henry Beverly, a financial analyst at Abbott Laboratories, took a personal leave of absence during which he began working for Cook County without informing Abbott. His leave was extended twice, but when he requested a third extension, Abbott had already filled his position and terminated his employment. Beverly sued Abbott, alleging racial discrimination and defamation, among other claims.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Abbott on some of Beverly’s claims, including those related to his termination, while allowing others to proceed to trial. The jury found in favor of Abbott on the remaining claims. Beverly appealed, challenging several pretrial, trial, and post-trial rulings.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that the reduction in Beverly’s job duties did not amount to a constructive discharge and that Abbott’s reason for terminating Beverly’s employment was not pretextual. The court also upheld the district court’s mid-trial judgment as a matter of law on Beverly’s defamation claim, finding that the statement in question was a non-actionable opinion. Additionally, the appellate court found no abuse of discretion in the district court’s trial rulings, including those related to impeachment attempts and the exclusion of certain evidence. The court concluded that Beverly’s arguments did not warrant a new trial and affirmed the district court’s judgment in full. View "Beverly v. Abbott Laboratories" on Justia Law

Charles Vavra, an employee of Honeywell International, Inc., was required to complete an online unconscious bias training. Vavra refused to participate in the training and was subsequently terminated. He then filed a lawsuit claiming that his termination was in retaliation for his opposition to the training and for his complaints about an email from the head of his business unit, which he found offensive.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Honeywell. The court found that Vavra's retaliation claims were without merit, leading to his appeal to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit reviewed the district court’s decision de novo. The court held that Vavra’s opposition to the training did not constitute protected activity under Title VII or the Illinois Human Rights Act because he did not have an objectively reasonable belief that the training violated the law. Vavra had not accessed the training or known its contents, making his belief speculative. Additionally, even if his complaints about the email were considered protected activity, Vavra failed to establish a causal connection between his complaints and his termination. The court noted that Honeywell had consistently sought Vavra’s compliance with the training requirement and only terminated him after his final refusal. The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Honeywell. View "Vavra v. Honeywell International, Inc." on Justia Law

The case revolves around Tondalaya Gamble, a Black physician who worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County and her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed that Cook County violated Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble argued that she was paid less than similarly situated non-Black physicians.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that no reasonable jury could find in Gamble’s favor on any of her claims. The court found that Gamble failed to establish that she was similarly situated to her chosen comparators, two white physicians, Bruce Rosenzweig and Karen Fish. The court noted that Rosenzweig was a part-time employee while Gamble was full-time, and that Fish had more experience and was hired to perform different duties.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that no reasonable jury could find that Gamble was similarly situated to Rosenzweig or Fish. The court noted that the part-time versus full-time distinction was not dispositive in and of itself, but that other differences, such as their different duties and experience, made them inapt comparators for Gamble’s discrimination claim. The court concluded that Gamble presented no other evidence suggesting that her pay or demanding work responsibilities were because of her race. View "Gamble v. County of Cook" on Justia Law