Employment Law- Title VII

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7^th Circuit Court of Appeals

Case Name: Charles Vavra v. Honeywell International, Inc.

Case No.: 23-2823

Officials: Scudder, St. Eve, and Kirsch, Circuit Judges.

Focus: Employment Law- Title VII

Charles Vavra, employed by Honeywell International, Inc., was instructed to complete an online unconscious bias training program. Vavra declined to participate in the training and subsequently faced termination. He alleged that his dismissal was in retaliation for refusing to partake in the training and for his objections to an offensive email from his business unit’s leader.

The Northern District of Illinois determined that Vavra’s claims of retaliation lacked merit, prompting his appeal to the Seventh Circuit.

The Seventh Circuit conducted a de novo review and concluded that Vavra’s opposition to the training did not qualify as protected activity under Title VII or the Illinois Human Rights Act because he did not possess an objectively reasonable belief that the training violated the law. Vavra had not accessed the training nor was he aware of its content, rendering his concerns speculative. Moreover, even if his objections to the email were deemed protected activity, Vavra failed to establish a causal link between his complaints and his termination. The court observed that Honeywell consistently sought Vavra’s compliance with the training requirement and terminated him only after his final refusal.

The Seventh Circuit upheld the district court’s decision to grant summary judgment in favor of Honeywell.

Affirmed.

Decided 07/10/24

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