Eaton v. Indiana Department of Corrections
657 F.3d 551
7th Cir.2011Background
- Eaton, a DOC corrections officer, sued DOC under Title VII alleging gender discrimination after termination/discipline related events.
- The district court granted summary judgment to DOC, concluding Eaton failed to prove a prima facie case.
- Eaton alleged a male comparator (Dennis Curtis) received more favorable treatment for similar conduct.
- Eaton was reassigned from watch tour to control room, then back to tour; she had a back injury and medical restrictions disclosed later.
- In March 2008, Eaton refused an assignment to Unit E-16, turned in her belt and badge, and was barred from reentry; DOC did not clearly show termination decision details.
- The Seventh Circuit reversed, finding reasonable jurors could view Eaton and Curtis as similarly situated and that the district court lacked sufficient basis to resolve pretext without more record evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case of discrimination established? | Eaton shows protected class, adverse action, and similarly situated comparator. | Curtis not sufficiently similar; no evidence of pre-termination comparator. | A reasonable factfinder could deem Curtis similarly situated; prima facie met. |
| Are Curtis and Eaton sufficiently similar to support a comparator analysis? | Curtis shared supervisor, unit, and issues; conduct comparable. | Differences in discipline history and conduct make them dissimilar. | Yes, they are sufficiently similar under flexible, common-sense standard. |
| Did the record permit resolution of pretext at summary judgment? | Pretext evidence exists in affidavits and treatment differences. | Termination reasons centered on quitting; no pretext evidence in record. | Pretext issue not resolved on record; remand appropriate. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (indirect proof framework for Title VII discrimination claims)
- Barricks v. Eli Lilly & Co., 481 F.3d 556 (7th Cir. 2007) (prima facie elements and burden shifting)
- South v. Illinois Environmental Protection Agency, 495 F.3d 747 (7th Cir. 2007) (context-based, flexible similarly situated analysis)
- Humphries v. CBOCS West, Inc., 474 F.3d 387 (7th Cir. 2007) (flexible, common-sense comparators guidance)
- Amrhein v. Health Care Service Corp., 546 F.3d 854 (7th Cir. 2008) (consideration of disciplinary history in comparators; limitations explained)
- Naik v. Boehringer Ingelheim Pharms., Inc., 627 F.3d 596 (7th Cir. 2010) (all material respects concept in similarly situated analysis)
- Patterson v. Avery Dennison Corp., 281 F.3d 676 (7th Cir. 2002) (definition of 'similarly situated' and factors considered)
- Hull v. Stoughton Trailers, LLC, 445 F.3d 949 (7th Cir. 2006) (same supervisor/standards among comparators guidance)
- Bio v. Federal Express Corp., 424 F.3d 593 (7th Cir. 2005) (same standards/experience considerations in comparators)