Tanika Beaulieu v. NewQuest Management of Illinoi
21-3001
7th Cir.Apr 1, 2022Background
- Plaintiff Tanika Beaulieu, an African‑American former customer‑service employee, sued NewQuest for Title VII race discrimination and retaliation after resigning in 2016.
- Allegations: supervisor Juan Salas subjected her to verbal abuse and close physical proximity; she overheard an ambiguous comment (“your people”) during a promotion interview; she was passed over for a promotion (which went to another African‑American), received lower pay than a longer‑tenured Hispanic coworker, and did not receive certain discretionary bonuses or remote‑work privileges.
- NewQuest had race‑neutral criteria for remote work and awarded bonuses/pay based on tenure and performance; several African‑American employees received bonuses and remote‑work privileges.
- A payroll/attendance error briefly recorded Beaulieu as a “no‑show,” was promptly corrected, but Beaulieu resigned soon after.
- In opposing summary judgment Beaulieu failed to comply with Federal Rule of Civil Procedure 56 and local Rule 56.1, asserted (without adequate sworn specifics) that a court reporter altered Salas’s deposition, and identified no missing discovery that was material. The district court entered summary judgment for NewQuest. The Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Compliance with summary‑judgment rules | Beaulieu argued the court should consider her factual assertions and alleged transcript alteration. | NewQuest argued her responses violated Rule 56 and Local Rule 56.1, so unsupported assertions don’t create disputes. | Court held district judge permissibly treated unsupported assertions as not creating disputed facts. |
| Race discrimination (hostile work environment, denial of promotion/pay/benefits) | Beaulieu said harassment, the “your people” remark, pay/bonus differences, and denial of remote work show racial motivation. | NewQuest said conduct and discretionary decisions were race‑neutral (tenure, performance, objective remote‑work criteria) and ambiguous remarks aren’t evidence of discrimination. | Court held evidence insufficient to show race was the motivating factor; summary judgment proper. |
| Retaliation for complaints about discrimination | Beaulieu relied on timing and incidents after her complaints to infer retaliation. | NewQuest argued timing and events do not show a causal link; actions followed neutral policies and significant delay undermines inference. | Court held timing and record do not suffice to infer retaliation; summary judgment proper. |
| Constructive discharge | Beaulieu argued the cumulative hostile conduct and the no‑show firing (later corrected) forced her resignation. | NewQuest argued the workplace was not so intolerable and the no‑show error was promptly fixed. | Court held the record does not show an unbearable working condition or that race doomed her prospects; no constructive discharge. |
Key Cases Cited
- Khungar v. Access Cmty. Health Network, 985 F.3d 565 (7th Cir. 2021) (standards for reviewing Title VII discrimination and for summary judgment).
- Patterson v. Ind. Newspapers, Inc., 589 F.3d 357 (7th Cir. 2009) (unsupported factual assertions can’t create genuine disputes at summary judgment).
- Williams v. Bd. of Educ., 982 F.3d 495 (7th Cir. 2020) (party must identify material discovery withheld to justify denial of summary judgment).
- Gorence v. Eagle Food Ctrs., Inc., 242 F.3d 759 (7th Cir. 2001) (isolated stray racial remarks do not establish discriminatory adverse employment actions absent impact on job conditions).
- Kidwell v. Eisenhauer, 679 F.3d 957 (7th Cir. 2012) (suspicious timing alone may be insufficient to prove retaliation where delays undermine causation).
- Fischer v. Avanade, Inc., 519 F.3d 393 (7th Cir. 2008) (standards for constructive discharge require an environment so intolerable a reasonable employee would feel forced to resign).