Grimaldo v. Mental Health Department of Human Services, 1:20-cv-07775

Plaintiff Susanna Grimaldo, a Mexican-American, sued her former employer, Illinois Department of Human Services (IDHS), alleging race and national origin discrimination after being demoted from a Social Worker II position at Chicago Read Mental Health Center in 2018.
Grimaldo's performance as a probationary Social Worker II was formally evaluated twice by her supervisor, Denise Blumenthal, and found deficient, mainly due to inadequate written documentation and core skills for the position.
As a result of these evaluations, Grimaldo was demoted back to her prior caseworker role.
Grimaldo filed the lawsuit pro se under Title VII, claiming her demotion was discriminatory.
IDHS moved for summary judgment, and Grimaldo failed to respond to the motion or comply with the local rules for summary judgment practice, leading the court to deem IDHS’s factual assertions admitted.
The court reviewed the record to determine if any triable issue of fact on discrimination existed given the undisputed facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discriminatory Demotion under Title VII	Grimaldo claimed she was demoted because of her race and national origin.	IDHS argued the demotion was solely due to documented performance failures, not discriminatory animus.	Court found no evidence supporting discrimination; summary judgment granted to IDHS.
Meeting Legitimate Job Expectations	Grimaldo disputed the accuracy of the negative evaluations but presented no evidence to support this.	IDHS presented evaluations and specific documented deficiencies in Grimaldo’s work.	Court found Grimaldo was not meeting job expectations—no prima facie case for discrimination.
Similarly Situated Employees	Grimaldo did not identify comparable employees allegedly treated better.	IDHS argued no such comparators existed or were presented.	Court found absence of comparators fatal to Grimaldo’s case.
Pretext for Discrimination	Implicitly, Grimaldo suggested the demotion was pretextual.	IDHS demonstrated extensive performance-based reasons; not pretextual.	Court found no evidence of pretext; only legitimate reasons for the employment action.

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard; nonmovant must show genuine issue for trial)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment if essential element lacking)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for Title VII claims)
Bostock v. Clayton Cty. Ga., 140 S. Ct. 1731 (statutory violation if decision would differ but for protected characteristic)