Nora Chaib v. State of Indiana
2014 U.S. App. LEXIS 3417
| 7th Cir. | 2014Background
- Chaib, a female French national and U.S. citizen, sued the State of Indiana (IDOC) for Title VII discrimination and retaliation after a probationary period at Pendleton Correctional Facility.
- She alleges harassment by male coworkers and training issues during probation; an inmate incident contributed to a hostile work environment claim ultimately unsuccessful.
- IDOC conducted investigations; a supervisor and an officer were reprimanded while Chaib was also reprimanded for alleged conduct unbecoming an officer.
- Chaib eventually resigned on FMLA leave in 2011 and filed multiple EEOC complaints before commencing the federal action.
- District court granted summary judgment for IDOC on all claims; Chaib appeals.
- Court analyzes whether there was adverse action, discriminatory intent, hostile environment, and retaliation under current Seventh Circuit standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discrimination: improper adverse action on gender/national origin | Chaib asserts adverse actions targeted her for gender/national origin. | IDOC argues no actionable adverse action linked to discrimination. | No reasonable inference of discrimination; no adverse action proven. |
| Discrimination: proof of discriminatory intent | Chaib argues there were comparators treated better and pretext evidence. | No similarly situated comparators; no convincing mosaic of discrimination. | Insufficient evidence of discriminatory intent; summary judgment upheld. |
| Hostile work environment | Harassment by coworkers created a hostile environment based on gender/national origin. | Employer liability requires negligent response; incidents involved coworkers with evidence of corrective action. | No basis for employer liability; no actionable hostile environment. |
| Retaliation | Chaib alleges adverse actions followed complaints about discrimination. | Adverse actions shown were not tied to protected activity; reprimand insufficient as adverse action. | Reprimand not actionable; no but-for causal link shown. |
Key Cases Cited
- Morgan v. SVT, LLC, 724 F.3d 990 (7th Cir. 2013) (standard for summary judgment and discrimination analyses)
- Nagle v. Village of Calumet Park, 554 F.3d 1106 (7th Cir. 2009) (definition of adverse action and causation in Title VII)
- Smart v. Ball State Univ., 89 F.3d 437 (7th Cir. 1996) (evaluations alone do not equate to adverse action)
- Oest v. Ill. Dep’t of Corr., 240 F.3d 605 (7th Cir. 2001) (protects against action solely on performance reviews)
- Perez v. Thorntons, Inc., 731 F.3d 699 (7th Cir. 2013) (mosaic framework for indirect discrimination proof)
- Burlington Northern Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (but-for causation standard for retaliation claims)
- University of Texas Southwestern Medical Center v. Nassar, 133 S. Ct. 2517 (2013) (retaliation requires but-for causation)