Johnson v. General Board of Pension & Health Benefits of the United Methodist Church, 733 F.3d 722

Johnson, a General Board employee (1999–2004), claimed race discrimination and retaliation under Title VII and §1981, plus sexual harassment.
Jung, General Board director, was named for §1981 claims; most claims were resolved in favor of defendants at summary judgment.
Two retaliation claims (March 2001 and January 2003 promotions) went to trial; the jury ruled for defendants.
Johnson alleged non-promotion decisions were discriminatory or retaliatory; district court granted summary judgment on most claims.
Johnson was terminated in March 2004 for recording conversations without consent; Board cited policy violations and Illinois law.
Post-trial motions for new trial and relief from judgment were denied; appeal followed challenging summary judgment and trial rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discrimination/retaliation summary judgment	Johnson argues genuine issues exist about discriminatory/retaliatory motive.	Board showed legitimate, non-discriminatory reasons; no pretext shown.	Summary judgment proper; no direct evidence or pretext shown.
August 2002/December 2002 promotions timeliness	Promotions were actionable despite disputed timeliness of August 2002 application; December 2002 disputed.	Promotions not timely applied for; absence of timely application forecloses claim.	Judgment for Board; no timely applications, no prima facie case.
March 2001/January 2003 discrimination claims	Evidence of discriminatory intent existed via leadership concerns and prior complaints.	Non-discriminatory reasons given; Johnson failed to show pretext.	Summary judgment affirmed; no pretext shown.
Termination discrimination/retaliation	Termination was retaliatory or discriminatory based on prior claims.	Termination due to recording coworkers’ conversations; policy and Illinois law violation.	Judgment affirmed; no pretext shown.
Sexual harassment claim	Video with nudity constituted harassment exposure.	Single minor incident insufficient for Title VII liability.	Summary judgment affirmed; incident not severe enough.

Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (direct vs. indirect proof framework)
Hudson v. Chicago Transit Auth., 375 F.3d 552 (7th Cir. 2004) (knowledge requirement for retaliation)
Grayson v. City of Chicago, 317 F.3d 745 (7th Cir. 2003) (prima facie burden and pretext framework)
Fischer v. Avanade, Inc., 519 F.3d 393 (7th Cir. 2008) (prima facie case for failure-to-promote under McDonnell Douglas)
Luckie v. Ameritech Corp., 389 F.3d 708 (7th Cir. 2004) (knowledge requirement in cat’s paw theories)
Byrd v. Illinois Dep’t of Public Health, 423 F.3d 696 (7th Cir. 2005) (cat’s paw theory limitations)
Lapka v. Chertoff, 517 F.3d 974 (7th Cir. 2008) (severity threshold for hostile environment)
Hostetler v. Quality Dining, Inc., 218 F.3d 798 (7th Cir. 2000) (severe conduct required for hostile environment)
Cowan v. Prudential Ins. Co. of America, 141 F.3d 751 (7th Cir. 1998) (single incident analysis for harassment)
United States v. Washington, 417 F.3d 780 (7th Cir. 2005) (trial management discretion)
United States v. Carrillo, 269 F.3d 761 (7th Cir. 2001) (Rule 51 objection timing and harmless error analysis)