7th Circuit Court of Appeals
Case Name: Nicole Bronson v. Ann & Robert H. Lurie Children’s Hospital of Chicago
Case No.: 22-1290
Officials: Sykes, Chief Judge, and Rovner and Jackson-Akiwumi, Circuit Judges.
Focus: Race Discrimination-Employment Law
Bronson has sued Ann & Robert H. Lurie Children’s Hospital of Chicago (“Lurie” or “the hospital”) and Susan Ruohonen, Lurie’s Director of Family Services, for race discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, and section 1981 of the Civil Rights Act of 1866, 42 U.S.C. § 1981. She also brought two state law claims for tortious interference with contract and defamation. The district court dismissed the Title VII and section 1981 claims along with the tortious interference claim and remanded the remaining defamation claim to state court. Bronson v. Ann & Robert H. Lurie Children’s Hosp. of Chicago, 2021 WL 1056847 (N.D. Ill. Mar. 18, 2021).
The gist of Bronson’s complaint is that from the beginning, Lurie and Ruohonen treated Bronson and Cooper, the first Black teachers who served at Lurie, in a discriminatory manner. Bronson alleges that Lurie staff, including Ruohonen in particular, took actions that made it more difficult for them to do their jobs, ostracized and demeaned them, subjected them to a hostile working environment, and attempted to have CPS discipline and/or remove them from Lurie.
Because the allegations in Bronson’s complaint establish that Lurie is not her de facto employer, she cannot sue Lurie under Title VII.