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