Rahn v. Board of Trustees of Northern Illinois University, 803 F.3d 285

Rahn and Genemetrix sue NIU Board of Trustees and NIU officers for Title VII race discrimination, retaliation, and copyright infringement, plus due process claims (the latter dismissed with prejudice).
District court granted summary judgment for defendants on discrimination, retaliation, and copyright, and Rahn appeals.
Facts are presented separately for discrimination/retaliation and copyright claims; this summary covers the discrimination/retaliation portion first, then copyright.
Rahn, a white applicant, alleges reverse discrimination in not being hired as tenure-track assistant professor in NIU ISYE; Regina Rahn served on the initial search committee but was removed due to potential conflict of interest as Rahn’s wife.
A search committee evaluated 82 applicants; Rahn was in the top ten but did not advance; Gary Chen was hired instead, with Regina later rejoining the committee for interviews and voting.
Rahn contends a Vohra remark favoring minority candidates shows discriminatory intent; he relies on an evaluation metric the committee used to compare candidates; the district court found no triable issue of pretext or discriminatory purpose; Rahn also pursued a grievance and EEOC complaint, and the district court held some claims waived.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rahn shows direct/indirect racial discrimination in hiring.	Rahn argues Vohra’s remark proves discrimination.	Chen was more qualified; no direct evidence; no pretext shown.	No triable issue; dismissal affirmed for discrimination.
Whether Rahn's retaliation claim survives.	NIU retaliated by harassing Rahn after his grievance.	Claim waived; conclusory/undeveloped; no legal support.	Waived; affirmed in favor of defendants.
Whether Rahn's copyright claims against ISYE 100 notes and Exelon PowerPoint survive.	Genemetrix authorship and ownership of course notes and derivative works.	Regina Rahn authored notes; Genemetrix ownership not established; other works improperly circumscribed; Exelon PPT claim waived.	Summary judgment affirmed; Regina sole author; plaintiffs fail to prove ownership or copyright infringement; Exelon PPT claim waived.

Langenbach v. Wal-Mart Stores, Inc., 761 F.3d 792 (7th Cir. 2014) (direct vs. circumstantial evidence standards for discrimination claims)
Ripberger v. Corizon, 773 F.3d 871 (7th Cir. 2014) (discourages reliance on perfunctory or undeveloped evidence of retaliation)
Hutt v. AbbVie Products, LLC, 757 F.3d 687 (7th Cir. 2014) (role of pretext in discrimination analyses)
Matthews v. Waukesha County, 759 F.3d 821 (7th Cir. 2014) (pretext and evidence under indirect method)
Schrock v. Learning Curve Int’l Inc., 586 F.3d 513 (7th Cir. 2009) (derivative works and ownership by operation of law)
Corley v. Rosewood Care Ctr., Inc. of Peoria, 388 F.3d 990 (7th Cir. 2004) (avoidance of broad, burdensome document review by reviewing court)
United States v. Dunkel, 927 F.2d 955 (7th Cir. 1991) (language on judicial preference for clear, supported arguments)
Ball v. City of Indianapolis, 760 F.3d 636 (7th Cir. 2014) (perfunctory factual or legal assertions waived on appeal)
Yasinskyy v. Holder, 724 F.3d 983 (7th Cir. 2013) (requirement of legal authority for pivotal arguments)
United States v. Lanzotti, 205 F.3d 951 (7th Cir. 2000) (perfunctory and undeveloped arguments are waived)
Seiser v. City of Chicago, 762 F.3d 647 (7th Cir. 2014) (context for de novo review standard in summary judgment)