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Race Discrimination

By: WISCONSIN LAW JOURNAL STAFF//July 8, 2024//

Race Discrimination

By: WISCONSIN LAW JOURNAL STAFF//July 8, 2024//

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7th Circuit Court of Appeals

Case Name: Tondalaya Gamble v. County of Cook

Case No.: 23-1531

Officials: Wood, Scudder, and Lee, Circuit Judges.

Focus: Race Discrimination

Tondalaya Gamble, an African American physician worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County, as well as her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed violations of Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and asserted that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble contended that she received lower compensation compared to similarly situated non-Black physicians.

In the Northern District of Illinois, summary judgment was granted in favor of the defendants. The court determined that no reasonable jury could find in favor of Gamble on any of her claims. It pointed out that Gamble did not demonstrate that she was similarly situated to her chosen comparators, Bruce Rosenzweig and Karen Fish, both white physicians. The court highlighted that Rosenzweig worked part-time while Gamble worked full-time, and Fish possessed more experience and was hired for different job responsibilities.

The Seventh Circuit agreed that no reasonable jury could conclude that Gamble was similarly situated to Rosenzweig or Fish. It emphasized that while the part-time versus full-time distinction alone was not determinative, the substantial differences in their roles and experience rendered them unsuitable comparators for Gamble’s discrimination allegations. The court concluded that Gamble had not presented any other evidence indicating that her compensation or challenging work responsibilities were influenced by her race.

Affirmed.

Decided 07/01/24

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