Brown v. County of Cook, 661 F.3d 333

Brown, a sergeant in the Cook County Sheriff's Office, was passed over for promotion to lieutenant during a two-year eligibility period (2003–2004).
Brown alleged the denial was based on his Republican political affiliation, his 1998 campaign donation to Sheahan's opponent, and his vote for that opponent.
Defendant Sheriff Sheahan allegedly did not know Brown or his political views prior to the suit, and Brown produced limited admissible evidence of discriminatory intent.
The district court granted summary judgment for defendants, applying Mt. Healthy burden-shifting analysis to determine if political affiliation was a motivating factor.
Brown attempted to amend to add a sex-discrimination claim, which the district court denied as untimely; the Seventh Circuit affirmed the grant of summary judgment.
Evidence included allegations of unrelated conduct by a promoted officer, hearsay challenges, and minimal direct proof linking promotions to political affiliation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mt. Healthy applies to Brown's political-discrimination claim	Brown argues his political affiliation was a motivating factor.	Sheahan contends there is no admissible evidence of political motive.	Mt. Healthy burden not met; no triable issue of fact on motive.
Whether Brown showed admissible evidence that decision-makers knew his political affiliation	Brown presents evidence suggesting awareness among decision-makers.	Evidence shows none of the decision-makers knew Brown's politics.	No admissible evidence established awareness of Brown's political affiliation.
Whether the district court properly denied Brown's motion to amend to add sex discrimination	Brown sought an equal-protection sex-discrimination claim.	Delay made amendment untimely; would not survive because not essential to a First Amendment claim.	Denial of amendment affirmed as untimely.

Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (U.S. Supreme Court, 1977) (burden-shifting framework for constitutional discrimination claims)
Rutan v. Republican Party of Illinois, 497 U.S. 62 (U.S. Supreme Court, 1990) (political affiliation as a basis for public employment decisions)
Visser v. Packer Eng’g Assocs., Inc., 924 F.2d 655 (7th Cir. 1991) (en banc: nonpolitical grounds can preclude liability when only political discrimination is alleged)
Greene v. Doruff, 660 F.3d 975 (7th Cir. 2011) (Mt. Healthy remains applicable to certain discrimination suits)
Cavel Int’l, Inc. v. Madigan, 500 F.3d 551 (7th Cir. 2007) (illustrative of Chicago context; references to nonessential arguments)