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Benuzzi v. Board of Educ. of City of Chicago
2011 U.S. App. LEXIS 14904
| 7th Cir. | 2011
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Background

  • Benuzzi is a long-serving CPS custodian, promoted to Grade V-II in 2004 and serving as engineer-in-charge at Pershing West Magnet School.
  • Cheryl Watkins, an African American principal, was hired in 2005 at Pershing and clashed with Benuzzi over scheduling and authority.
  • Watkins issued cautions and a 15-day suspension process for various incidents; Benuzzi repeatedly contested through union appeals.
  • Benuzzi sustained a period of missed time and a shoulder-to-desk escalation that culminated in multiple suspensions and a formal disciplinary process.
  • Benuzzi filed EEOC charges in 2006-2007 alleging gender (and later race, age, disability) discrimination and retaliation; this suit followed after a right-to-sue letter in 2009.
  • The district court granted summary judgment to Watkins/Board on discrimination claims, but the retaliation claim was later remanded for trial after finding genuine issues of material fact regarding post-deposition actions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Board/Watkins violated Title VII gender discrimination law. Benuzzi argues pretext and disparate treatment based on gender. Board/Watkins contend actions were nondiscriminatory and based on conduct; no gender animus shown. Affirmed summary judgment on discrimination; no evidence of gender animus.
Whether Board/Watkins retaliated against Benuzzi for EEOC filings and related actions. Benuzzi asserts protected activity caused adverse actions; timing supports causation. Defendants contend actions were disciplinary or administrative; timing alone insufficient. Vacated summary judgment on retaliation; remanded for trial due to genuine issues of material fact.

Key Cases Cited

  • McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for proving discrimination using indirect method)
  • Burlington Northern & Santa Fe Ry. v. White, 548 U.S. 53 (2006) (materially adverse actions standard for retaliation claims)
  • Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (pretext analysis and ultimate burden on plaintiff)
  • Vance v. Ball State Univ., 646 F.3d 461 (7th Cir. 2011) (hostile environment and discrimination standards in Seventh Circuit)
  • Lang v. Ill. Dept. of Children & Family Servs., 361 F.3d 416 (7th Cir. 2004) (causation and setup in retaliation analyses)
  • Lloyd v. Swifty Transp., Inc., 552 F.3d 594 (7th Cir. 2009) (adverse action not just a written reprimand without impact)
  • Casna v. City of Loves Park, 574 F.3d 420 (7th Cir. 2009) (causation and timing in retaliation cases)
  • Argyropoulos v. City of Alton, 539 F.3d 724 (7th Cir. 2008) (timing and inference in causal links)
  • Johnson v. Cambridge Indus., Inc., 325 F.3d 892 (7th Cir. 2003) (adverse actions and terms/conditions of employment)
Read the full case

Case Details

Case Name: Benuzzi v. Board of Educ. of City of Chicago
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Jul 21, 2011
Citation: 2011 U.S. App. LEXIS 14904
Docket Number: 10-3021
Court Abbreviation: 7th Cir.