Bob-Maunuel v. Chipotle Mexican Grill, Inc., 10 F. Supp. 3d 854

Plaintiff Tubonimi Bob-Manuel is a 55-year-old Black Nigerian-born US citizen who worked for Chipotle Oak Park from Nov 16, 2008 to Mar 11, 2011.
Defendant Chipotle operates multiple fast-casual Mexican restaurants; Oak Park is overseen by a General Manager who hires, trains, promotes, and terminates employees.
Plaintiff alleges race, national origin, age discrimination, and retaliation under Title VII, §1981, and the ADEA, plus ADA discrimination and retaliation and Illinois workers’ compensation retaliation.
Plaintiff’s early training was halted by managers who supervised and ultimately terminated him after multiple performance issues and alleged policy violations.
Defendant asserts termination was for poor performance, insubordination, and food-safety violations, and that other similarly situated employees were treated differently.
The court grants summary judgment for some claims and denies for others, including discriminatory termination, failure-to-promote/train, disability discrimination, and retaliation to varying extents; count IX is dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discrimination: direct/indirect proof of race, national origin, and age claims	Bob-Manuel contends pretext; disparate treatment in promotion/training and termination	Training/promotion/termination decisions were based on performance and policy violations	Discrimination claims survive; triable issues on pretext exist.
ADA claims: disability discrimination and failure to accommodate	Hernia and eye disease constitute disabilities; denial of training/promotion and termination were discriminatory	Some conditions not disabilities; failure-to-accommodate not adequately pled or proven	Disability discrimination survives; failure-to-accommodate claim dismissed.
Retaliation: protected activity versus adverse actions (termination, raises, promotions)	Terminated after EEOC/internal complaints; evidence of pretext and increased scrutiny	Timing insufficient for retaliation; no new discriminatory conduct after complaints	Retaliation claim based on termination survives; denial of raises/promotions not sustained.
State-law retaliatory discharge (IWCA)	Discharge for workers’ compensation activity; causation shown	Illinois causation standards require stronger evidence; mere pretext insufficient	Count VI dismissed; no causation shown.

Atanus v. Perry, 520 F.3d 662 (7th Cir. 2008) (claims under Title VII/§1981/ADA analysis share framework)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. Supreme Court 1973) (burden-shifting framework for indirect discrimination claims)
Adreani v. First Colonial Bankshares Corp., 154 F.3d 389 (7th Cir. 1998) (pretext evidence supports retaliation/ discrimination findings)
Dey v. Colt Constr. & Dev. Co., 28 F.3d 1446 (7th Cir. 1994) (detailed refutation of events supports disputing employer’s reasons)
Gordon v. United Airlines, Inc., 246 F.3d 878 (7th Cir. 2001) (honest belief in reasons; not required to be reasonable; pretext can defeat summary judgment)
Merillat v. Metal Spinners, Inc., 470 F.3d 685 (7th Cir. 2006) (circumstantial evidence can establish discriminatory intent even if alone insufficient)
Hobgood v. Ill. Gaming Bd., 731 F.3d 635 (7th Cir. 2013) (convincing mosaic of circumstances may defeat summary judgment on discrimination)
Troupe v. May Dept Stores Co., 20 F.3d 734 (7th Cir. 1994) (circumstantial evidence categories for direct-method discrimination)
Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (overlaps between direct/indirect proof; pretext and similarly-situated evidence)