Race and Sex Discrimination

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7^th Circuit Court of Appeals

Case Name: Kimberly Barnes-Staples v. Robin Carnahan

Case No.: 22-3275

Officials: Sykes, Chief Judge, and Flaum and Lee, Circuit Judges.

Focus: Race and Sex Discrimination

Kimberly Barnes-Staples applied for the position of Real Estate Director with the General Services Administration (GSA). However, the GSA opted to hire another candidate, leading Barnes-Staples to file a lawsuit against the GSA, alleging discriminatory practices during the interview process based on her race and sex, contravening Title VII of the Civil Rights Act. The district court ruled in favor of the GSA, granting summary judgment.

Barnes-Staples contended that the GSA deviated from its internal anti-discrimination procedures, allowing the hiring of a less qualified candidate. She argued that she was the superior candidate, asserting that the GSA’s claim of the other candidate’s superior qualifications was pretextual. Additionally, Barnes-Staples claimed there was a systematic pattern of discrimination against Black candidates and employees within the GSA.

However, the Seventh Circuit determined that Barnes-Staples was not “clearly better qualified” than the candidate selected. It found no evidence that the GSA tailored interview questions to favor the chosen candidate, and there was no indication that the GSA violated its own guidelines during the interview process. The court also observed that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to substantiate her claim of systemic discrimination.

The Seventh Circuit affirmed the decision to grant summary judgment in favor of the GSA. Additionally, it noted that Barnes-Staples had waived her sex discrimination claim, as she did not adequately develop this argument before the district court.

Affirmed.

Decided 12/18/23

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