Golla v. Office of the Chief Judge of Cook County, 875 F.3d 404

Plaintiff Francis Golla (white) worked for the Office of the Chief Judge, Cook County; reinstated in 1996 at Grade 14 after an earlier termination and settlement; held title Law Clerk I and performed administrative duties in Social Services until resigning in 2013.
Deotis Taylor (African-American) worked for the Office earlier, held Grade 22 as of 1998, left and was rehired in 2006 as Legal Systems Analyst at Grade 22 in Social Services; performed administrative duties similar to Golla’s and retired in 2013.
Both appeared in the Social Services directory as Administrative Assistant and handled overlapping tasks (e.g., SCERT intakes), but had different formal pay grades established years earlier in other departments.
Golla learned of the pay disparity in 2009, filed administrative charges with the IDHR/EEOC, received a right-to-sue letter, and sued under Title VII (reverse racial discrimination). A § 1983 claim was dismissed by the district court.
Defendants produced evidence that Social Services did not set pay grades (employees retained prior grades), listed many others with similar duties at lower grades, and that the supervisor Whitehead had no pay-setting authority nor knowledge of the disparity until told by Golla.
District court granted summary judgment for Defendants; the Seventh Circuit affirmed, evaluating the evidence under Ortiz’s integrated-review standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence permits a reasonable jury to find race caused pay disparity	Golla: Taylor (African‑American) performed similar work but was paid more; only plausible cause is race	Defendants: Pay grades were set years earlier in other departments; Social Services did not control pay; no evidence linking race to pay decisions	Held: No — insufficient evidence that race caused the disparity
Whether supervisor Whitehead's remarks show racial animus affecting pay	Golla: Whitehead's comments reflect racial animus in department supporting inference of discrimination	Defendants: Whitehead had no pay authority, ambiguous remark not tied to pay, and she denied knowledge of disparity	Held: Remarks insufficient — not shown to relate to pay decisions or race-based motive
Whether a pattern or practice of reverse discrimination existed in Social Services	Golla: Disparity between him and Taylor indicates broader discriminatory practice	Defendants: Presented multiple employees of both races with similar duties at lower pay; no pattern favoring African‑Americans	Held: No — no evidence of systemic reverse discrimination
Proper legal standard for evaluating mixed direct/indirect evidence	Golla: Relied on traditional direct/indirect proof distinctions	Defendants: Argued evidence, viewed as a whole, is insufficient	Held: Court applies Ortiz (evaluate evidence as whole); under that standard evidence fails to permit a reasonable jury verdict for Golla

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for indirect proof in discrimination cases)
Mills v. Health Care Serv. Corp., 171 F.3d 450 (7th Cir.) (discussion of modified McDonnell Douglas framework)
Ortiz v. Werner Enters., Inc., 834 F.3d 760 (7th Cir.) (evidence must be considered as a whole rather than separated into "direct" and "indirect")
David v. Bd. of Trs. of Cmty. Coll. Dist. No. 508, 846 F.3d 216 (7th Cir.) (indirect method remains a means to organize circumstantial evidence)
Cole v. Bd. of Trs. of N. Ill. Univ., 838 F.3d 888 (7th Cir.) (standard of review for summary judgment)
Merillat v. Metal Spinners, Inc., 470 F.3d 685 (7th Cir.) (requiring connection between alleged discriminatory remarks and adverse action)