Employment Discrimination

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7^th Circuit Court of Appeals

Case Name: Sisawat Singmuongthong v. Edwin Bowen

Case No.: 21-3021

Officials: Rovner, Brennan, and Scudder, Circuit Judges.

Focus: Employment Discrimination

Singmuongthong identifies himself as an individual of Laotian national origin with a tan complexion. He served as a correctional officer at Sheridan from 1998 to 2013, at which point he advanced to the position of lieutenant within the same institution. In 2016, Singmuongthong received a promotion and took on the role of assistant warden of operations at a newly established facility named Kewanee. This transition came with a five percent increase in his salary. Notably, the warden at Kewanee, Williams, faced an investigation in 2018 regarding inappropriate behavior of a sexual nature involving subordinate staff, resulting in Williams’ termination. During this investigation, it was revealed that Singmuongthong had exhibited challenges in making sound administrative decisions, failed to report instances of inappropriate sexual conduct, and spent an excessive amount of time in the company of subordinate staff at bars.

Singmuongthong expressed his interest in the warden position to the regional deputy chief, Funk. However, he was not selected for the role due to concerns regarding his association with Williams and apprehensions about his decision-making abilities. Following a subsequent investigation into a separate accusation of sexual harassment, Singmuongthong’s employment was terminated.

Singmuongthong initiated legal action, asserting claims of racial, color, and national origin discrimination, along with allegations of retaliation, under 42 U.S.C. 1981. The district court granted the defendants summary judgment. Singmuongthong chose to appeal solely concerning his claims of pay inequality and failure to secure a promotion. The Seventh Circuit rejected Singmuongthong’s contention of pretext.

Affirmed

Decided 08/08/23

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