By: Derek Hawkins//October 3, 2016//
7th Circuit Court of Appeals
Case Name: Jerome Cole v. Board of Trustees of Northern Illinois University, et al
Case No.: 15-2305
Officials: POSNER, KANNE, and HAMILTON, Circuit Judges
Focus: Retaliatory Termination
Plaintiff Jerome Cole has worked for Northern Illinois University in the Building Services Department since 1998. He is African-American, and he alleges that beginning in 2009, he experienced race discrimination, retaliation, and a hostile work environment, including the discovery of a hangman’s noose in his newly assigned workspace. He sued the university’s board of trustees and eleven individual university employees asserting violations of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e–2, –3, and the Equal Protection Clause of the Fourteenth Amendment. The district court granted summary judgment to the defendants. We affirm. The hostile work environment claim presents the closest question, but Cole has not shown a basis for employer liability for the alleged harassment. Cole also has not offered evidence that would allow a reasonable trier of fact to find that he was subjected to disparate treatment based on his race. His retaliation claim fails because he has not offered evidence that he engaged in protected activity.
Affirmed