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Employment – Retaliation

7th Circuit Court of Appeals

Case Name: Elaine Scaife v. United States Department of Veterans Affairs

Case No.: 21-1152

Officials: KANNE, ROVNER, HAMILTON, Circuit Judges.

Focus: Employment – Retaliation

Scaife worked as a Human Resources Classifier at the Roudebush Veterans Affairs Medical Center in Indianapolis. A department lead there called her a racial slur outside of her presence and her supervisor allegedly treated her differently based on her gender. Scaife complained to human resources, but the human resources officer responded with a counseling email disapproving of Scaife’s approach to handling workplace issues. Scaife received the counseling email a few weeks after she had already filed an internal Equal Employment Opportunity (EEO) complaint claiming a hostile work environment. She later transferred to a different VA facility and sued her employer for retaliation, constructive discharge, and a hostile work environment based on gender and race. The district court granted summary judgment for her employer on all claims.

Affirmed

Decided 09/27/22

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