Rodgers v. White, 2011 U.S. App. LEXIS 18288

Rodgers, a long-time Illinois secretary of state employee, was fired in 2006 but later reinstated after arbitration.
Rodgers, the only Black employee in a large crew, claims two white managers targeted him for termination due to race.
Disciplinary decisions centered on two incidents: alleged misuse of state property and improper overtime recording; only Rodgers faced severe discipline.
The Inspector General's report and subsequent internal reviews contributed to the termination decision against Rodgers, while similarly situated white employees received lighter treatment.
Rodgers pursued Title VII and § 1981/§ 1983 claims; the district court granted summary judgment for defendants, later reversed as to dismissal on summary judgment.
On appeal, the Seventh Circuit held that a jury could reasonably infer discrimination based on evidence comparing Rodgers to his supervisor and another white employee, and vacated for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Direct evidence of discrimination	Rodgers argues circumstantial bits show discriminatory intent.	Court should require direct evidence of intent for discrimination claim.	Insufficient direct evidence; not decisive on discrimination.
Prima facie case under indirect method	Rodgers demonstrates he was treated worse than similarly situated white employees.	Rodgers must identify white comparators with similar misconduct and circumstances.	Rodgers established a prima facie case by showing harsher discipline than Rusciolelli, a supervisor, and that comparators were similarly situated.
Appropriate comparator for similarly situated analysis	Rusciolelli (supervisor) is a valid comparator despite rank differences.	Supervisors are ordinarily poor comparators due to rank and duties.	Supervisor comparator can be valid where based on shared misconduct, duties, and disciplinary context.
Pretext and genuine reasons for termination	Defendants’ stated reasons were false or pretextual and race was the true motive.	Reasons were legitimate and non-pretextual explanations.	Evidence shows pretext; defendants’ reasons are not credible and race could be inferred as the motive.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes the burden-shifting framework for discrimination claims)
Luster v. Ill. Dep't of Corr., 652 F.3d 726 (7th Cir. 2011) (merges second and fourth elements in race-discrimination cases when comparing to white counterparts)
Weber v. Univ. Research Ass'n, Inc., 621 F.3d 589 (7th Cir. 2010) (discrimination analysis in unequal discipline contexts)
Elkhatib v. Dunkin Donuts, Inc., 493 F.3d 827 (7th Cir. 2007) (properly identifying similarly situated employees for comparison)
Hasan v. Foley & Lardner LLP, 552 F.3d 520 (7th Cir. 2008) (evidence of discrimination may rely on circumstantial inferences when combined)