Risa Stegall v. Andrew M. Saul, 943 F.3d 1124

Background

In 2010 Stegall interviewed for a Social Security Administration (SSA) service representative job; she alleges an offer was made during the interview and then rescinded after she disclosed physical and mental disabilities.
SSA denied making an interview offer, concluded Stegall was "not motivated for public service" based on her interview answers, and selected two other applicants (one accepted elsewhere; one with a disability accepted the SSA position).
Stegall exhausted administrative remedies, filed suit alleging race and disability discrimination, then dismissed her race and mental-disability claims before trial.
A jury found Stegall had a physical disability, that SSA regarded her as disabled, and that SSA failed to hire her — but also found she would not have been hired even without her physical disability.
On appeal Stegall argued the verdict was against the manifest weight of the evidence and that the district court abused its discretion by admitting certain evidence (a 2015 VHA job application and evidence that the hired applicant had a disability).
The Seventh Circuit affirmed: Stegall waived sufficiency challenges by failing to move under Rules 50/59, and the court did not abuse its discretion in admitting the contested evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of sufficiency-of-the-evidence challenge (manifest-weight/new-trial)	Stegall contends the jury verdict is against the manifest weight of the evidence and seeks a new trial.	SSA notes Stegall never moved for judgment as a matter of law under Rule 50(a) nor renewed under Rule 50(b), nor filed a timely Rule 59 motion.	Waiver: Stegall failed to preserve sufficiency challenge; appeal cannot succeed on manifest-weight grounds.
Admissibility of 2015 VHA application showing no disability	Irrelevant and prejudicial; subsequent statements do not prove her 2010 condition and she omitted disability out of fear of discrimination.	Relevant to whether Stegall was disabled in 2010; contradictions in later records are explainable and probative.	Admissible: subsequent medical statements and exams are relevant to a claimant’s condition during the earlier period (Halvorsen, Stark). Court did not abuse discretion.
Admissibility of evidence that SSA hired an applicant with a disability	Irrelevant and prejudicial; showing a member of the protected class was hired undermines discrimination claim.	Relevant to rebut discriminatory-intent inference; hiring an applicant with a disability is probative though not outcome-determinative.	Admissible: evidence bears on intent and weight; Stegall did not show substantial prejudice or impact on outcome.
Showing prejudice from evidentiary rulings	Admission of the above evidence prejudiced the verdict.	To obtain relief Stegall must show a significant chance the rulings affected the trial outcome.	No prejudice shown: record contains ample non-discriminatory reasons (hired applicant more qualified; interview answers) supporting the verdict.

Key Cases Cited

Pickett v. Sheridan Health Care Ctr., 610 F.3d 434 (7th Cir.) (standard for upholding civil jury verdicts when supported by record)
Empress Casino Joliet Corp. v. Balmoral Racing Club, Inc., 831 F.3d 815 (7th Cir.) (Rule 50(a)/(b) renewal requirement to preserve sufficiency challenges)
Carmody v. Bd. of Trs. of the Univ. of Ill., 893 F.3d 397 (7th Cir.) (abuse-of-discretion review for in limine rulings)
Rogers v. Chicago, 320 F.3d 748 (7th Cir.) (reversible evidentiary error requires effect on substantial rights)
Hill v. Tangherlini, 724 F.3d 965 (7th Cir.) (discussion of evidentiary rulings and prior case law)
United States v. Hudson, 843 F.2d 1062 (7th Cir.) (relevance analysis for subsequent evidence bearing on earlier condition)
Halvorsen v. Heckler, 743 F.2d 1221 (7th Cir.) (later diagnosis may be probative of earlier impairment)
Stark v. Weinberger, 497 F.2d 1092 (7th Cir.) (diagnosis years later can inform question of onset)
O'Connor v. Consol. Coin Caterers Corp., 517 U.S. 308 (U.S. Supreme Court) (context on relevance of hiring within protected class in discrimination claims)
Maurer v. Speedway, LLC, 774 F.3d 1132 (7th Cir.) (significant-chance standard for showing evidentiary rulings affected outcome)
Smith v. Hunt, 707 F.3d 803 (7th Cir.) (same)