Title VII – Title VII– Reverse Discrimination

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7^th Circuit Court of Appeals

Case Name: Diane Runkel v. City of Springfield

Case No.: 21-2418

Officials: HAMILTON and KIRSCH, Circuit Judges.

Focus: Title VII – Title VII– Reverse Discrimination

Plaintiff Diane Runkel worked as the assistant purchasing agent for the city of Springfield, Illinois. In early 2018, when the purchasing agent announced that he planned to leave the position, Runkel asked to be considered for promotion to the top job in the office. Runkel, who is white, later found out that she had not been selected and that the City instead promoted a black candidate, Kassandra Wilkin, who had been working under Runkel’s supervision. As an apparent consolation prize, Runkel was offered a substantial $5,000 per year raise in salary. When told she did not receive the promotion, however, Runkel became upset, told a city official that she believed the hiring was discriminatory, and caused a disturbance in the office. Runkel later filed a charge of race discrimination with the U.S. Equal Employment Opportunity Commission (EEOC). The account of her reaction to the decision is disputed, but after telling the City she planned to file the charge, Runkel was disciplined and the promised raise was revoked. Soon after that, she retired.

The City moved for summary judgment, and the district court granted the motion.

According to the court, Runkel has offered evidence that would allow a reasonable jury to find that the City retaliated against her for her protected activity claiming what she believed was race discrimination, and the City’s evidence does not conclusively foreclose such a finding.

Reversed

Decided 10/18/22

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