Sawyer v. Columbia College, 864 F. Supp. 2d 709

Sawyer, an African-American male, was a Columbia College student in 2002, 2007, and 2008 with cited grades changing from D/C to A- in a class.
In 2008 Sawyer began work through a College work-study program at Youth Communication Chicago; he also took College courses there.
Sawyer challenged a grade (Introduction to Marketing) and alleged racial disparities in treatment in June 2008, prompting administrative correspondence.
On June 23, 2008 Sawyer was involved in a physical altercation at Youth Communication; supervisors documented the incident and reported to College officials.
Beverly Anderson, the College’s Assistant Dean, investigated the June 23 incident along with prior 2007 New Orleans and February 15, 2007 incidents involving Sawyer.
Anderson concluded Sawyer and Ginger Bush would be terminated from Youth Communication and suspended from Columbia College for one year; Sawyer was notified July 8, 2008.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title VII sex discrimination standard	Sawyer claims discrimination based on sex via termination/suspension.	No direct evidence; burden-shifting shows legitimate, non-discriminatory reason	Grant for College on Title VII sex discrimination
Title VI race discrimination	Race-based discrimination due to alleged comments and grade treatment; pretext possible.	No link between race and decision; Sawyer failed to meet expectations; Bush similarly situated.	Grant for College on Title VI race discrimination
Title VI retaliation	Retaliation for filing discrimination complaint caused suspension.	No evidence Anderson knew of complaints; action based on June 23 incident and history.	Grant for College on Title VI retaliation

Atanus v. Perry, 520 F.3d 662 (7th Cir. 2008) (direct/indirect proof pathways in Title VII discrimination)
Isbell v. Allstate Ins. Co., 418 F.3d 788 (7th Cir. 2005) (convincing mosaic of circumstantial evidence can show intent)
Essex v. United Parcel Serv. Inc., 111 F.3d 1304 (7th Cir. 1997) (McDonnell Douglas framework in discrimination cases)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (burden-shifting framework for proving discrimination)
Dandy v. United Parcel Service, Inc., 388 F.3d 263 (7th Cir. 2004) (convincing mosaic, direct/indirect proof framework)
Gorence v. Eagle Food Centers, Inc., 242 F.3d 759 (7th Cir. 2001) (circumstantial evidence and inference framework)
Hudson v. Wal-Mart Stores, Inc., 412 F.3d 781 (7th Cir. 2005) (workplace misconduct as basis for discrimination ruling)
Palmer v. Circuit Court of Cook County, 117 F.3d 351 (7th Cir. 1997) (summary judgment in retaliation/fighting in workplace context)
Pantoja v. American NTN Bearing, 495 F.3d 840 (7th Cir. 2007) (prima facie case and post-termination inference considerations)
Johnson v. University of Wisconsin-Eau Claire, 70 F.3d 469 (7th Cir. 1995) (causal link and protected activity in retaliation claims)