Chontel Miller v. Polaris Laboratories LLC, 797 F.3d 486

Miller, an African-American sample processor at Polaris (Aug 2009–Apr 2010), consistently logged far fewer samples than Polaris's 260/day target and was discharged for poor productivity.
Miller complained in September 2009 that a coworker called her “the colored girl”; an internal HR investigation followed.
Coworker Young testified that supervisors Ballard and coworker Kemp used racial epithets directed at Miller and thereafter made Miller’s work harder (e.g., assigning trays with mixed customers, missing labels, or rearranging samples).
Miller presented testimony she and Young observed Ballard/Kemp manipulating Miller’s trays and that Ballard refused to train or assist Miller after the complaint.
Polaris maintained production numbers justified termination and offered affidavits describing tray assignment procedures that, it said, made deliberate tampering unlikely.
The district court initially denied summary judgment on discrimination (cat’s paw) but later granted summary judgment to Polaris on all claims; the Seventh Circuit reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller raised a genuine dispute that coworkers with discriminatory animus (Ballard, Kemp) proximately caused her firing under the cat’s paw theory	Ballard and Kemp uttered racial epithets and repeatedly sabotaged Miller’s trays and refused to train her, which plausibly depressed her productivity and caused termination	Polaris: Miller’s overall low productivity cannot be explained by a few observed incidents; no systematic tampering; decisionmakers relied on objective numbers	Reversed — jury could find Ballard/Kemp harbored animus and their meddling could be a proximate cause of termination; summary judgment improper
Whether Miller raised a genuine dispute for retaliation based on complaints about discrimination	Miller engaged in protected activity (complaint to supervisors); adverse action followed; timing and post‑complaint mistreatment permit an inference of retaliation	Polaris: Poor performance (numbers) was the real reason; no causal link to complaints	Reversed — evidence suffices to create a triable issue that Ballard/Kemp retaliated by undermining her work after the complaint

Smith v. Bray, 681 F.3d 888 (7th Cir.) (discusses cat’s paw theory and subordinate bias)
Staub v. Proctor Hosp., 562 U.S. 411 (2011) (supervisor’s discriminatory act that is a proximate cause can impose employer liability)
Hutchens v. Chicago Bd. of Educ., 781 F.3d 366 (7th Cir.) (cat’s paw liability principles)
Matthews v. Waukesha Cty., 759 F.3d 821 (7th Cir.) (biased subordinate providing input can support liability)
Langenbach v. Wal‑Mart Stores, Inc., 761 F.3d 792 (7th Cir.) (direct and circumstantial evidence standards in Title VII cases)
Mintz v. Caterpillar Inc., 788 F.3d 673 (7th Cir.) (same standards for Title VII and §1981)
Nichols v. Mich. City Plant Planning Dep’t, 755 F.3d 594 (7th Cir.) (treats biased subordinate’s actions as direct evidence)
Castro v. DeVry Univ., Inc., 786 F.3d 559 (7th Cir.) (elements of Title VII retaliation claim)
Jajeh v. County of Cook, 678 F.3d 560 (7th Cir.) (contrast where more precise proof defeated inference of tampering)