Latice Porter v. City of Chicago
2012 U.S. App. LEXIS 23041
| 7th Cir. | 2012Background
- Porter, a Christian civilian employee in the City of Chicago’s Field Services Section, sought Sunday-based accommodations to attend church; the city’s scheduling changes were driven by operational needs and balance of shifts; Hegarty suggested a watch change to accommodate Sundays, which Porter did not pursue; Porter asked to join Sunday/Monday days-off group and later requested a Saturday change for ministry classes; after returning from medical leave, Porter was placed in Friday/Saturday days-off group to balance groups, with no evidence of intent to target religious practice; Porter complained of harassment and filed CCHR/EEOC charges, leading to district court summary judgment for the City finding reasonable accommodation and no triable evidence of discrimination or retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to accommodate whether watch change was reasonable | Porter contends City failed to offer a viable accommodation | City offered watch-change option as reasonable accommodation | Yes; watch-change was a reasonable accommodation |
| Disparate treatment proof of religious discrimination | Porter argues adverse actions targeted religion | Actions were for operational balance, not religious bias | No genuine issue of material fact on adverse action element |
| Hostile work environment claim viability | Harassment based on religion impacted work | Conduct not severe or pervasive | Not actionable; no objective offensiveness or pervasiveness established |
| Retaliation claim sufficiency | Assignments after protected activity were retaliatory | No causal link shown due to timing and other factors | Summary judgment affirmed; no causal link established |
Key Cases Cited
- Ansonia Bd. of Educ. v. Philbrook, 479 U.S. 60 (U.S. 1986) (reasonable accommodation not required at all costs; must eliminate conflict)
- Rodriguez v. City of Chi., 156 F.3d 771 (7th Cir. 1998) (dialogue with employer can satisfy accommodation duty)
- Reed v. Great Lakes Cos., 330 F.3d 931 (7th Cir. 2003) (reasonableness of accommodations; undue hardship standard)
- Washington v. Ill. Dep’t of Revenue, 420 F.3d 658 (7th Cir. 2005) (adverse-action standard in retaliation context; context matters)
- Burlington Northern Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (retaliation standard broader than discrimination; contextual analysis)
- Oest v. Ill. Dep’t of Corrections, 240 F.3d 605 (7th Cir. 2001) (broad definition of adverse employment action)