Mildred Chatman v. Board of Education of the City
5 F.4th 738
7th Cir.2021Background
- Mildred Chatman, a 62-year-old African American former Chicago Public Schools employee, was laid off in 2009 and later settled a discrimination suit with the Board that guaranteed her interviews for vacancies through December 31, 2015.
- Under the settlement she identified open positions; she interviewed at five schools (Beasley, Earle, Mireles, McDade, Ray) but received no offers during the settlement period.
- Beasley claim conceded untimely; Earle claim lacked documentary support and was held time-barred by the district court.
- Mireles: principal interviewed Chatman, later offered the job to a younger candidate (K.D.) but the position was eliminated for budgetary reasons before K.D. started.
- McDade and Ray: principals hired other candidates (some younger, some older; mix of races); hiring decisions were supported by specific nondiscriminatory reasons (volunteer experience, familiarity with students, strong recommendations, candidate later obtained required license).
- Procedural posture: District court granted summary judgment for the Board on statute-of-limitations, discrimination (Title VII/ADEA), and retaliation claims; Seventh Circuit affirmed, finding insufficient evidence of discrimination or retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Earle claim | Chatman: accrual date uncertain; claim within 300 days if measured from learning of nonhire | Board: record lacks any evidence of Earle hiring action within 300 days; only an email promising scheduling | Held: Earle claim time-barred—no evidence plaintiff timely filed with EEOC |
| Discrimination (Mireles — ADEA) | Chatman: Board’s budgetary excuse is pretext because principal offered job to younger K.D. before elimination | Board: position was genuinely cut; K.D. never started, so budget reason is not a lie | Held: No pretext—budget elimination credible; summary judgment for Board |
| Discrimination (McDade & Ray — ADEA/Title VII) | Chatman: she was better qualified; hires were younger or non‑African American | Board: selected candidates had legitimate advantages (volunteer experience, alumni ties, recommendations, licensure obtained) | Held: No pretext—legitimate nondiscriminatory reasons supported hires |
| Retaliation (Mireles, McDade, Ray) | Chatman: prior EEOC charge caused nonhire; Mireles principal’s vague lawsuit question supports retaliatory motive | Board: evidence of causation absent; principals (McDade/Ray) denied knowledge; Mireles question too vague and budget cut undermines retaliation inference | Held: No but‑for causation shown; retaliation claim fails |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for burden‑shifting in failure‑to‑hire discrimination claims)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (2013) (retaliation requires but‑for causation)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant may show absence of evidence to carry summary judgment burden)
- Ortiz v. Werner Enters., Inc., 834 F.3d 760 (7th Cir. 2016) (evaluate all evidence together in a single pile)
- Salas v. Wis. Dep’t of Corr., 493 F.3d 913 (7th Cir. 2007) (EEOC‑filing statute of limitations is an affirmative defense; ties favor plaintiff only if evidence inconclusive)
- Jajeh v. Cnty. of Cook, 678 F.3d 560 (7th Cir. 2012) (budget cuts can be legitimate nondiscriminatory reasons)
- Russell v. Acme‑Evans Co., 51 F.3d 64 (7th Cir. 1995) (pretext means a phony reason; employer lie supports pretext analysis)