Robert Bless v. Cook County Sheriff's Office, 9 F.4th 565

Bless was a Cook County Sheriff’s Office deputy (1996–2013) who, after a 2008 on‑duty car crash, received injured‑on‑duty (IOD) status and disability benefits while also practicing law and serving as an elected Republican county commissioner.
The Sheriff’s Office requires prior approval for secondary employment; Bless submitted some forms but did not have documented approvals for the period Jan 31, 2009–Dec 9, 2010, while on IOD.
Cook County Risk Management discovered Bless driving and working while on IOD; OPR investigated and concluded Bless lied about having submitted secondary‑employment requests.
The Merit Board found Bless had unauthorized secondary employment, violated driving restrictions, and lied to investigators, and it ordered his termination in May 2013.
Bless sued under 42 U.S.C. § 1983 (political‑retaliation and race discrimination) and Title VII (race); the district court denied Bless’s attempt to depose Sheriff Dart and granted summary judgment for defendants.
The Seventh Circuit affirmed: it found no abuse of discretion in denying Dart’s deposition and held the record insufficient to create triable issues on political retaliation or race discrimination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deposition of Sheriff Dart	Dart’s testimony might yield evidence of knowledge/motivation (meeting where Bless discussed accident, offices, politics)	Dart was not involved in OPR/Merit Board processes; interrogatories suffice; deposition would be burdensome	Denial affirmed — district court did not abuse discretion; written discovery adequate and Dart unlikely to produce unique admissible evidence
Political‑retaliation (First Amendment)	Timing of events (election 2008, transfers after return, release from consent decree, charges filed 2011) supports inference of retaliation against Republican political activity	Termination was for non‑political reasons: unauthorized secondary employment, driving while medically restricted, and lying to investigators	Summary judgment affirmed — timing was not ‘‘very close’’ and intervening misconduct undercuts causal inference; defendants’ reasons stand absent evidence of pretext
Race discrimination (white plaintiff)	White plaintiff alleges comparators (nonwhite) received more lenient treatment and several decisionmakers were nonwhite	No background circumstances showing an inclination to discriminate against whites; proposed comparators not materially similar	Summary judgment affirmed — plaintiff failed the threshold requirement to show background circumstances or similarly situated comparators and did not prove defendants’ reasons were pretextual

Stagman v. Ryan, 176 F.3d 986 (7th Cir. 1999) (standard for deposing public officials and appellate review of discovery rulings)
Olivieri v. Rodriguez, 122 F.3d 406 (7th Cir. 1997) (public officials need not give depositions absent reason to expect admissible evidence)
Heffernan v. City of Paterson, 136 S. Ct. 1412 (2016) (First Amendment protects public‑employee political rights)
Kidwell v. Eisenhauer, 679 F.3d 957 (7th Cir. 2012) (burden‑shifting framework for First Amendment public‑employee claims)
Yahnke v. Kane County, 823 F.3d 1066 (7th Cir. 2016) (Elements of prima facie First Amendment retaliation claim)
Loudermilk v. Best Pallet Co., 636 F.3d 312 (7th Cir. 2011) (suspicious timing requires very close temporal proximity)
Formella v. Brennan, 817 F.3d 503 (7th Cir. 2016) (proof needed for white‑plaintiff Title VII/§ 1983 discrimination claims)
Hague v. Thompson Distrib. Co., 436 F.3d 816 (7th Cir. 2006) (examples of background circumstances supporting white‑plaintiff discrimination claims)