Equal Employment Opportunity-Discrimination

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7^th Circuit Court of Appeals

Case Name: Rochelle Hambrick v. Kilolo Kijakazi

Case No.: 22-3217

Officials: Flaum, Brennan, and St. Eve, Circuit Judges.

Focus: Equal Employment Opportunity-Discrimination

Born in 1970, Hambrick, an African American woman, boasts a 35-year tenure at the Social Security Administration (SSA). In 2016, her professional journey took a turn when her supervisor reassigned her, albeit within the same managerial role and corresponding pay scale. Following this reassignment, she claims to have endured a barrage of negative treatment from both her superiors and her colleagues. This mistreatment, according to Hambrick, constitutes a form of harassment fueled by the intersection of her age and race.

Despite her professional experience and commitment, Hambrick faced disappointment in her attempts to explore new roles within the organization. One notable instance involved a position for which her supervisor opted to hire a younger, Caucasian male candidate, attributing the decision to perceived shortcomings in her collaborative skills. Adding to her grievances, her immediate supervisor’s recommendation came “with reservations.” Beyond this, Hambrick voiced concerns about her excessive workload and the expedited career progression of younger, non-black SSA employees. She also noted that her achievements in reducing the backlog of cases went unnoticed by her supervisors, leaving her without due recognition.

In response to her escalating concerns, Hambrick initiated Equal Employment Opportunity (EEO) complaints. Regrettably for Hambrick, these complaints did not sway the tides in her favor; they were resolved in favor of the SSA.

When the matter reached the district court, a multifaceted evaluation took place. The court acknowledged Hambrick’s administrative exhaustion of claims centered around the SSA’s failure to promote her, her performance evaluation downgrade, and her repeated non-selection for positions in 2021—perceived by her as retaliation for her EEO complaints. However, despite this comprehensive review, the court ultimately concluded that Hambrick had not convincingly demonstrated unlawful discrimination. The court’s rationale lay in the perception that the “totality of undisputed facts” merely encapsulated routine workplace disagreements. Hambrick’s expressed dissatisfaction with her supervisors, her workload burdens, and her lack of acknowledgment were deemed insufficient to create a hostile work environment, as determined by the court.

This verdict was subsequently upheld by the Seventh Circuit. The court echoed the sentiment that the incidents Hambrick pointed out lacked the severity or pervasiveness required to substantiate her claims. Moreover, the court pointedly mentioned the absence of a compelling connection between these incidents and the protected characteristics of her age or race, as required for a discrimination case.

Affirmed.

Decided 08/18/23

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