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Title VII Violation – Retaliation Claim

7th Circuit Court of Appeals

Case Name: Catrina Bragg v. Munster Medical Research Found

Case No.: 21-2913

Officials: Wood, St. Eve, and Jackson-Akiwumi, Circuit Judges.

Focus: Title VII Violation – Retaliation Claim

After completing a 90-day orientation program for newly licensed nurses, Bragg was denied a fulltime position as a Registered Nurse (RN) at Community Hospital, which is operated by Munster Medical Research Foundation. Community then transferred her to Hartsfield Village, another of Munster’s facilities, where her pay was lower. Bragg, who is Black, believes that these adverse employment actions were based on racially discriminatory evaluations of her performance and were retaliatory. She sued Munster under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., but the district court granted summary judgment in favor of the defendants. The Seventh Circuit affirmed, acknowledging that Bragg’s reports of racial insensitivity are typical of the challenges Black women face in the workplace. Bragg’s evidence would not allow a trier of fact to conclude that her employer (Community) denied her a full-time position and transferred her for impermissible reasons, rather than for its stated concern about deficiencies in her performance. The court ruled that Bragg did not present enough evidence to permit a trier of fact to find that her transfer to Hartsfield was the result of impermissible racial bias.


Decided 01/17/23

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