Seventh Circuit Upholds Decision in Favor of Employer in Race Discrimination Case

Two African-American nurses filed a complaint against their hospital-employer alleging that the hospital had discriminated against them on the basis of race and retaliated against them for their complaints about racial discrimination in violation of Title VII. Throughout their employment, both nurses complained about their working conditions. They alleged their supervisors failed to make the changes that they recommended and treated them less favorably due to their race. The nurses also alleged that they were retaliated against due to their complaints of race discrimination.

The District Court granted summary judgment in favor of the employer finding that the nurses had not presented a triable issue of fact. The Seventh Circuit affirmed, finding that the nurses had not presented any evidence showing that they were treated differently from a similarly situated employee. The Seventh Circuit also found that simply because the employer did not respond favorably to the nurses' complaints, did not create a circumstantial case of discrimination. It reasoned that Title VII does not protect against personal animosity or juvenile behavior and that the fact that “someone disagrees with you or declines to take your advice does not, without more, suggest that they discriminated against you.”

The Seventh Circuit also affirmed the District Court’s dismissal of the retaliation claim. The Court found that the nurses had not provided any evidence of an adverse action by their employer. The Court reasoned that personality conflicts or generally getting the “cold shoulder” from a boss is not an adverse action that can serve as a basis of a Title VII claim.

It's not against the law to be a jerk. Not every negative actions by a supervisor can lead to a claim under Title VII or even corresponding state law. This case demonstrates that Title VII has limitations as to how far it will protect employees in certain circumstances. As always, employers are reminded to ensure that their policies, procedures, and practices comply with federal and state law, and that employees and management alike receive required training concerning the employer's anti-discrimination, anti-harassment, and anti-retaliation policies.  

For more information visit the U.S. Court of Appeal website.

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