Title VII of the Civil Rights Act of 1964-First Amendment

7^th Circuit Court of Appeals

Case Name: Becky Spengler v. Cooperative Educational Service Agency 7

Case No.: 25-2532

Officials: Brennan, Chief Judge, and Scudder, and Jackson-Akiwumi, Circuit Judges.

Focus: Title VII of the Civil Rights Act of 1964-First Amendment

Spengler, a special education administrator, was employed by a Wisconsin educational service agency that provided support to multiple school districts. After several years, her supervisors, acting in response to directives from the Wisconsin Department of Public Instruction, required employees to adopt an “equity mindset,” which emphasized recognizing personal biases and addressing systems perceived to perpetuate white supremacy. The administrator objected to what she viewed as an ideological mandate and declined to fully embrace the initiative. Her resistance prompted concerns from the Department of Public Instruction, increased pressure on the agency, and ultimately her demotion to a lower-paying position.

The administrator filed suit in the Eastern District of Wisconsin, alleging race discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause. She also asserted a First Amendment claim, alleging that she was demoted in retaliation for her protected speech and beliefs. The district court granted summary judgment for the defendants on the Title VII and Equal Protection claims, concluding that the evidence did not support a finding that race was a motivating factor in the demotion because the challenged equity requirements were imposed on employees regardless of race. The court also rejected her First Amendment speech claim and concluded that her First Amendment claim based on her beliefs had not been adequately pleaded.

The Seventh Circuit concluded that no reasonable jury could determine that race motivated the administrator’s demotion and that she had not engaged in objectively protected activity for purposes of her retaliation claim. The court likewise affirmed the dismissal of her First Amendment claim based on protected speech but found that she had adequately pleaded a First Amendment claim alleging retaliation for her protected beliefs and remanded that claim to the district court for further proceedings.

Affirmed and remanded.

Decided 07/08/26

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