United States Court of Appeals For the Seventh Circuit
Evidence – retaliation — EEOC filings
In a trial alleging retaliation for opposing discrimination, the district court properly admitted documents filed with the local Equal Opportunity Commission.
“The MEOC documentation helps to illustrate the cause-and-effect relation between action on Phillips’s complaint at the MEOC and the harsh retaliatory treatment endured by Blue. For example, the MEOC made an initial probable cause determination on Phillips’s complaint on August 3, 2006. Four days later, Blue received a letter denying her overtime opportunities. She was entitled to present the probable cause determination to show, as she argued at trial, that the denial of overtime was ‘a reaction to her participation in that case.’ Similarly, a few days after IBEW learned of the MEOC’s scheduled public hearing in Phillips’s case, Blue was formally disciplined in several ways. In all, the documents from Phillips’s MEOC file were relevant to Blue’s allegation that IBEW’s unfair treatment of her was a response to her participation in Phillips’s complaint, and the district court did not abuse its discretion by finding that this evidence was more probative of this causal relationship than prejudicial to IBEW.”
Appeal from the United States District Court for the Western District of Wisconsin, Conley, J., Wood, J.