Wise v. Lessie Bates Davis Neighborhood House, 3:21-cv-01265

Plaintiff Reona Wise, an African American woman, sued Lessie Bates Davis Neighborhood House (LBD) asserting §1981 claims for race/color discrimination and retaliation; other claims were dismissed earlier; the case reached summary judgment for LBD.
Wise was hired in 2016, promoted to Vice President overseeing grants/programs, and received periodic raises; staff complaints arose about her management style and misuse of program funds and time.
In Oct. 2017 Wise signed a vendor contract without CEO/CFO approval, was placed on 45 days paid administrative leave, and then put on a 12/18/2017 Performance Improvement Plan (PIP); the PIP was vacated by the new interim CEO on 1/11/2018.
In 2018 Wise again executed two agreements (May and June 2018) committing LBD to obligations without prior CEO approval, and LBD learned her son volunteered in a program she supervised; District 189 later ended a partnership with LBD over program concerns.
Wise filed an EEOC charge in December 2017 (alleging sex and retaliation, not race/color) and a later charge after her August 17, 2018 termination; LBD contends termination was for repeated unauthorized contractual commitments and performance/management issues.
The court granted summary judgment to LBD, finding Wise failed to establish a prima facie §1981 discrimination or retaliation claim and that LBD had legitimate, nonpretextual reasons for termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race/color discrimination under 42 U.S.C. §1981	Wise says she was discriminated against because of her race/color (medium–dark complexion) and points to derogatory remarks and adverse treatment.	LBD says Wise cannot show she met legitimate job expectations and has no similarly situated nonprotected comparator; termination was for valid, nonracial reasons.	Court: Granted summary judgment for LBD — Wise failed to prove she met expectations and produced no comparator; discrimination claim dismissed.
Retaliation under 42 U.S.C. §1981	Wise asserts her EEOC charge and internal grievances were protected activity and her later termination was retaliatory.	LBD contends termination was for independent, legitimate reasons (repeated unauthorized contracts, staff complaints, program issues); long gap and intervening PIP undercut causation.	Court: Granted summary judgment for LBD — termination not shown to be causally connected to complaints; legitimate nondiscriminatory reasons prevail.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (describes burden-shifting framework for discrimination claims)
Ortiz v. Werner Enters., Inc., 834 F.3d 760 (7th Cir. 2016) (directs courts to evaluate all evidence together rather than segregating direct and indirect evidence)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (retaliation adverse-action standard; action that might deter a reasonable worker)
Mintz v. Caterpillar Inc., 788 F.3d 673 (7th Cir. 2015) (elements of prima facie employment discrimination case)
Tart v. Ill. Power Co., 366 F.3d 461 (7th Cir. 2004) (categories of materially adverse employment actions)
Madlock v. WEC Energy Group, Inc., 885 F.3d 465 (7th Cir. 2018) (need for objective showing that employer action was materially adverse)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden allocation)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for granting summary judgment)