Summary Judgment – Title VII Violation

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7^th Circuit Court of Appeals

Case Name: Diane Trahanas v. Northwestern University

Case No.: 21-3278

Officials: Easterbrook, Hamilton, and Brennan, Circuit Judges.

Focus: Summary Judgment – Title VII Violation

Trahanas worked as a research technician in a medical lab. After almost three years, she took medical leave and eventually her employment was terminated. Based on statements made to her by her supervising doctor and coworkers, she sued her former university employer, Northwestern, and the doctor. She claimed they created a hostile work environment in violation of Title VII and retaliated against her under the Family and Medical Leave Act and the Americans with Disability Act. She also alleged that, contrary to Illinois law, the defendants defamed her and intentionally caused her emotional distress. The district court granted summary judgment to the defendants. Trahanas’s voluntary decision not to return to work or extend leave does not amount to a tangible employment action. The court noted Northwestern’s anti-harassment policy and that Trahanas “unreasonably failed to take advantage of any preventive or corrective opportunities” to avoid harm. Trahanas cannot show that her leave played a motivating factor in Northwestern’s decision to terminate her employment.

Affirmed.

Decided 04/07/23

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