Employment Law-Retaliation

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7^th Circuit Court of Appeals

Case Name: Songie Adebiyi v. South Suburban College

Case No.: 22-2516

Officials: Scudder, Kirsch, and Jackson-Akiwumi, Circuit Judges.

Focus: Employment Law-Retaliation

Songie Adebiyi, formerly the Vice President of Student Services at South Suburban College in Illinois, was terminated in 2019 purportedly due to performance issues. Adebiyi contended that her dismissal was in retaliation for filing a charge with the United States Equal Employment Opportunity Commission (EEOC) and the Illinois Department of Human Rights. She brought forth a lawsuit against the college and its president, alleging racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as well as breach of contract.

The Northern District of Illinois granted summary judgment to the college and its president, asserting that Adebiyi had not established a causal link between her discrimination charge and her termination. The court concluded that the evidence did not support Adebiyi’s claim of retaliation. Dissatisfied with the ruling, Adebiyi appealed, contending that the district court erred in dismissing her Title VII retaliation claim and in denying her motion to amend the complaint and conduct further discovery.

The Seventh Circuit aligned with the lower court’s determination that Adebiyi had failed to prove a causal connection between her protected activity and the adverse employment action. Additionally, the appellate court found no indication of pretext in the college’s grounds for termination or any suspicious timing between Adebiyi’s filing of her EEOC and IDHR charge and her termination. Furthermore, it found no abuse of discretion in the district court’s refusal of Adebiyi’s motion to amend the complaint and conduct additional discovery.

Affirmed.

Decided 04/17/24

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