United States Court of Appeals For the Seventh Circuit
Employment — retaliation
Summary judgment was properly granted to an employer on the employee’s claim of retaliation, where the employee’s discrimination claim was filed 8 years earlier, and the employee committed multiple acts of misconduct.
“[W]e do not think that a reasonable jury could find that the report’s conclusions referred to Collins’s EEOC complaint. Of course, that does not mean that the report’s conclusions were correct. Collins denies making the statements that the report attributes to her, and we must assume, at this stage, that Collins is telling the truth. Stice’s report was sloppy, and perhaps it was also mistaken or even unfair. But Title VII does not forbid sloppy, mistaken, or unfair terminations; it forbids discriminatory or retaliatory terminations. See Brown v. Advocate S. Suburban Hosp., 700 F.3d 1101, 1106 (7th Cir. 2012). Collins has provided evidence showing, at most, that the report’s conclusions were wrong. But she has not provided anything—apart from mere speculation—that the report’s conclusions were wrong because of Collins’s EEOC complaint. As a result, the Red Cross was entitled to summary judgment.”
Appeal from the United States District Court for the Northern District of Illinois, Kapala, J., Kanne, J.