Toy A. Collins v. American Red Cross
2013 U.S. App. LEXIS 4749
| 7th Cir. | 2013Background
- Collins, African-American, worked for the American Red Cross since 1998; terminated July 16, 2007 after internal investigation found substantiated misconduct.
- Collins filed a 2006 EEOC discrimination charge; received right-to-sue letter February 2007 but did not sue then.
- June 2007 investigation by HR (Stice) interviewed eight witnesses; Collins denied the allegations.
- Stice concluded the allegations were substantiated and recommended termination; district court granted summary judgment for Red Cross.
- Collins argued retaliation for the 2006 EEOC charge and disparate treatment based on race; district court and now the court of appeals analyze both claims.
- Court reviews summary judgment de novo, considering whether permissible inferences could yield a jury verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retaliation: causal link between protected activity and termination | Stice's substantiated findings imply retaliation due to EEOC filing | No evidence ties report conclusions to EEOC complaint; report concerns office tension, not retaliation | No reasonable jury could find a causal link; summary judgment affirmed for Red Cross |
| Discrimination: whether evidence supports direct or indirect claim of racial discrimination | McDonnell Douglas framework or direct evidence of racial animus from report context | Red Cross's reasons supported by misconduct findings; no pretext or direct discrimination shown | No pretext or direct evidence of discrimination; district court affirmed |
Key Cases Cited
- Brown v. Advocate S. Suburban Hosp., 700 F.3d 1101 (7th Cir. 2012) (pretext standard; wrong conclusions insufficient for discrimination)
- Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (direct method framework and pretext analysis)
- Naficy v. Ill. Dep’t of Human Servs., 697 F.3d 504 (7th Cir. 2012) (direct vs indirect methods; proof standards)
- Arizanovska v. Wal-Mart Stores, Inc., 682 F.3d 698 (7th Cir. 2012) (summary judgment de novo review; evidence standard)
- Boumehdi v. Plastag Holdings, LLC, 489 F.3d 781 (7th Cir. 2007) (mosaic of circumstantial evidence; weaknesses in testimony)
- Dickerson v. Bd. of Trs. of Cmty. Coll. Dist. No. 522, 657 F.3d 595 (7th Cir. 2011) (discrimination standards; evaluating employer evaluations)
- Jones v. Union Pac. R.R. Co., 302 F.3d 735 (7th Cir. 2002) (demonstrates that alleging inaccuracy alone is insufficient to prove pretext)