Thomas Hobgood v. Illinois Gaming Board, 731 F.3d 635

Hobgood, a senior special agent for the Illinois Gaming Board, faced extensive investigations, disciplinary proceedings, and eventual termination, though later reinstated.
Hobgood assisted fellow employee John Gnutek in Title VII and RICO litigation against the Gaming Board, prompting alleged retaliation by Board officials.
The district court granted summary judgment to defendants, holding Hobgood failed to show the protected activity caused a material adverse action.
Hartigan’s internal investigation broadened beyond alleged illegal recording to Hobgood’s assistance to Gnutek, and suggested pretextual motives.
State Police and State’s Attorney’s Office concluded no evidence supported Hobgood’s illegal-recording charge, but internal investigations continued against him.
The Illinois Civil Service Commission ultimately found limited misconduct (possession of Trent’s file) and imposed a suspension rather than termination; Hobgood was reinstated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Hobgood show but-for causation for retaliation?	Hobgood’s mosaic shows retaliation for aiding Gnutek.	Board’s action based on independent, legitimate concerns about misconduct.	Material facts remain; trial needed.
Does the mosaic of circumstantial evidence create a genuine dispute on motive?	Bits collectively show retaliatory intent.	Isolated pieces are insufficient to prove motive.	Summary judgment inappropriate; jury to decide.
Are the defendants entitled to qualified immunity on the First Amendment retaliation claim?	Right to be free from retaliation for protected activity was violated.	No clearly established right violation for delivery of information or actions taken.	No qualified immunity; right clearly established.

Rhodes v. Illinois Dep’t of Transp., 359 F.3d 498 (7th Cir. 2004) (convincing mosaic framework for circumstantial evidence)
Troupe v. May Dep’t Stores Co., 20 F.3d 734 (7th Cir. 1994) (circumstantial evidence framework for retaliation)
Harper v. C.R. England, Inc., 687 F.3d 297 (7th Cir. 2012) (direct method and prima facie framework; pretext concepts)
Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (alleged retaliation and direct method considerations; pretext)
Brown v. Advocate South Suburban Hosp., 700 F.3d 1101 (7th Cir. 2012) (direct retaliation standard; causation considerations)
Kasten v. Saint-Gobain Performance Plastics Corp., 703 F.3d 966 (7th Cir. 2012) (supervisor statements and retaliation inference; pre-suspension context)
Spiegla v. Hull, 371 F.3d 928 (7th Cir. 2004) (public employee protections; public concern)
Zorzi v. County of Putnam, 30 F.3d 885 (7th Cir. 1994) (public employee rights; retaliation standards)