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Keywords

lawsuitplaintiffappealmotionsummary judgmentdiscrimination

Related Cases

Stephens v. Erickson, 569 F.3d 779, 106 Fair Empl.Prac.Cas. (BNA) 1036, 92 Empl. Prac. Dec. P 43,618

Facts

Lesley Stephens, an employee of the City of Chicago, interviewed for four promotions between August and October 2004 but was passed over each time. He alleged that the City denied him these promotions in retaliation for his previous lawsuit regarding racial discrimination and for his complaints about discrimination within his department. The City maintained a standard hiring process where interviewers rated candidates based on their qualifications, and Stephens was consistently rated lower than the successful candidates, who had more relevant experience.

Lesley Stephens began working for the City of Chicago in 1979, when he was hired as a truck driver by the Department of Fleet Management. In December 1985, Stephens was promoted to acting foreman. Around one year later, in early 1987, the City appointed Stephens to be acting assistant superintendent at Fleet, a position that required him to supervise approximately 144 employees at twelve locations. Later that same year, Stephens was reassigned to his original position as a truck driver, and in early 1988, he suffered a back injury and took disability leave.

Issue

Did the City of Chicago retaliate against Lesley Stephens by denying him promotions due to his prior lawsuit and complaints of discrimination?

Rule

To establish a retaliation claim under Title VII and § 1981, a plaintiff must show that they engaged in a protected activity, suffered a materially adverse action, and that there is a causal connection between the two.

Analysis

The court found that Stephens failed to demonstrate a causal link between his protected activity and the City's actions. The interviewers who rated the candidates did not know about Stephens's prior lawsuit or complaints, and they provided legitimate reasons for their ratings. The court concluded that the promotional process was fair and that Stephens's claims of retaliation were unsupported by evidence.

Conclusion

The Court of Appeals affirmed the district court's grant of summary judgment in favor of the City, concluding that Stephens did not provide sufficient evidence to support his claims of retaliation.

Who won?

City of Chicago; the court found that Stephens did not demonstrate retaliation or materially adverse actions.

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Keywords

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