After enduring a lengthy campaign of religious harassment from his supervisor, Wam-iq Sattar was first transferred to a different section, then placed on probationary status, and finally was terminated from his position as an engineer for Motorola. Believing that the supervisor’s religious intolerance lay behind his termination, Sattar sued Motorola and his two immediate superiors, raising claims under Title VII of the Civil Rights Act, 42 U.S.C. § 2000e-2(a)(l), and under state law. The district court granted summary judgment to the defendants on Sattar’s Title VII claims and dismissed the state law claims without prejudice, declining to retain them under its supplemental jurisdiction. Although, taking the facts as Sattar presents them, it is plain that the supervisor behaved in a manner entirely unbecoming a person in a society that requires tolerance for the religious views of all, we agree with the district court that the summary judgment record does not support Sattar’s claim.
I
Sattar is a native of Bangladesh, which until 1971 was known as East Pakistan. Like most of his compatriots, Sattar began life as a Muslim. Some twenty years ago, he moved to the United States, where he attended college. After graduation, he married a Lutheran woman and began regularly attending Lutheran services. In January 1990, Motorola hired Sattar to work as a staff engineer in the Personal Communications Network Group (PCN) at Motorola’s Arlington Heights, Illinois, facility. Shortly thereafter, Motorola hired Arif Pardesi, who became Sattar’s immediate supervisor. Par-desi is from Pakistan (formerly known as West Pakistan). Like Sattar, he was raised in the Muslim faith, but Pardesi remained a devout — one might say zealous — Muslim. *1167 Jerry Campbell, the other individual Sattar named as a defendant, was Pardesi’s supervisor.
Almost immediately after he started to work with Sattar, Pardesi began hounding him about his abandonment of Islam. The summary judgment record is replete with examples of Pardesi’s badgering. Two weeks into their relationship, Pardesi warned Sattar that he (Pardesi) would watch Sattar “like a hawk.” Pardesi constantly advised Sattar to follow the teachings of the Koran and to join Pardesi and other Muslims who worked at Motorola for weekly prayer sessions in Pardesi’s office. Pardesi sent literally hundreds of e-mail messages to Sattar between January 1992 and June 1993 with citations to the Koran and dire warnings of the divine punishments that awaited those who turned their back on Islam.
Pardesi also made no secret of his view that Sattar’s fate at Motorola lay in Pardesi’s hands. On one occasion, he told Sattar that “Allah is the solution to all problems” and that “nonbelievers will be condemned to hell.” When, in the summer of 1990, Pardesi promoted several of Sattar’s coworkers and passed over Sattar, he told Sattar that “we need Khaliphas to lead the mission” and that Sattar would never be a Khalipha. (According to Islamic teachings, a Khalipha is a divinely inspired leader.) Going further, Pardesi expressly told Sattar that if he returned to Islam it would improve his standing in the eyes of his superiors.
Sattar responded by asking Pardesi to approve his transfer to another department — a request Pardesi flatly refused. Next, in June 1990 Sattar made a formal complaint about Pardesi’s harangues to a human resources manager at Motorola. He made a second complaint in December 1990 to Motorola’s human resources director, Martin Rogers. At that time, Sattar informed Rogers that Pardesi had forced a manager to downgrade a performance review of Sattar’s work. The original draft, which Sattar had seen, had placed him at a 2.2 (satisfactory) level, but Pardesi ordered the writer to rewrite it and place Sattar at a 1.5 (unsatisfactory) level. Sattar also told Rogers about his unsuccessful efforts to transfer to another department. Rogers promised to investigate but never did so.
Other signals Sattar was receiving from Motorola were more positive. In 1991, he was temporarily loaned to another group, in which his performance was good enough to prompt the supervisor to write a complimentary letter for the file. Pardesi, however, refused to include the letter when the supervisor sent it to him, commenting again to Sattar that he didn’t see him “as a Khalipha.” Sattar also received two certificates from the Motorola Award and Recognition Program for his “outstanding achievement,” one in November 1991 and the other in October 1992. In two other performance reviews, he received “satisfactory” ratings.
Notwithstanding those signs of success, after his return in August 1991 to Pardesi’s direct supervision, Pardesi told Sattar that he had been ranked lowest in his grade level at a managers’ rating and ranking session. These were meetings at which all the higher managers in the organization assembled to discuss the strengths and weaknesses of each employee. These rankings were independent of the performance reviews. In early 1992, Pardesi assigned Sattar to a particularly difficult project, which at least three other engineers had attempted without'success. Sat-tar, too, had trouble with it. In December of that year he finally succeeded in transferring away from Pardesi’s control. He informed his new supervisor, David Yen, that he believed that Pardesi was “out to get him” for not being a devout Muslim. For the first few months in Yen’s section, Sattar was finishing up the project for Pardesi. Pardesi removed Sattar from the project in February 1993, with the comment that his work was “technically deficient,” and replaced him with another engineer. That person was also unable to finish the work, which was reassigned to yet another engineer.
In April or May 1993, at another group ranking and rating session, Pardesi expressed the opinion that Sattar lacked competence in the use of á particular computer language, that he had logged false overtime, and that he had taken credit for work written by another engineer. By this time, of course, Yen was Sattar’s supervisor. The consensus at the meeting was that Sattar ranked at the bottom of all job grade E09 *1168 engineers in his group. In keeping with Motorola’s policies, Yen decided that Sattar should be placed in a Performance Improvement Plan (PIP), in which his work would be monitored closely. At Motorola, if an employee placed in a PIP successfully completes the program he may continue working; if not, he is fired.
Yen wrote the first draft of Sattar’s PIP, but with input from Pardesi, according to Sattar. Yen asserted that he would have put Sattar on a PIP even if Sattar had not been having problems on the Pardesi project. In June 1993, Yen left the picture and Lisa Vecchio became Sattar’s PIP supervisor. Vecchio redrafted the part of the PIP that described the specific tasks Sattar had to accomplish in order to “pass” the program, but she otherwise continued on the course Yen had set. Sattar, in the meantime, informed Christine Ioriatti, the person who supervised both Yen and Vecchio, about Par-desi’s actions and threats. Ioriatti referred him (once again) to the human resources department, where he told Rogers of Parde-si’s harassing e-mails. Within weeks of those meetings, the e-mails stopped. Soon thereafter, Pardesi transferred to a position in the United Arab Emirates.
Sattar completed the PIP on October 18, 1993. He alleges that Vecchio told him on that day that “you passed the PIP,” but that he would not be notified formally until October 21. On the latter date, he learned that he was being terminated immediately. The PIP finding was mixed: while he had successfully completed the technical portions of the program, he was found to be lacking in “leadership, consistency, initiative, and responsibility skills.” At the time Vecchio and Ioriatti met with him to pass along the bad news, Sattar alleges, Ioriatti told him that “Mr. Pardesi’s activities have caused this termination; you should have done something about Pardesi’s harassment long ago,” such as obtaining a transfer away from Pardesi.
II
Sattar named as defendants not only Motorola, but also Pardesi and Campbell “individually and in their corporate capacity.” The district court correctly dismissed the complaint against the individual defendants. It is by now well established in this court that “a supervisor does not, in his individual capacity, fall within Title VII’s definition of employer.”
Williams v. Banning,
Sattar’s claim in this case is that Motorola discharged him because of his religion. He has not alleged, and we therefore do not consider, whether he might have been entitled to relief for the on-the-job harassment he endured under the so-called “hostile environment” theory of discrimination. See
Venters v. City of Delphi,
Generally, when either the district court or • this court decides whether a Title VII plaintiff can defeat an employer’s motion for summary judgment, we identify two methods of proof the plaintiff might use. The first is the “direct” method, under which the plaintiff may show (either through direct
*1169
or circumstantial evidence) that the employer’s decision to take the adverse job action was motivated by an impermissible purpose (race, sex, religious animosity, etc.). See
Wallace v. SMC Pneumatics, Inc.,
The distinction between the direct method, at least when circumstantial evidence is the vehicle for proving it, and the indirect method is an elusive one. Furthermore, when this court has reviewed employment discrimination cases after a full trial, we have made it clear that the various steps of the
McDonnell Douglas
method are essentially a heuristic device, not a rule of law. See
Achor v. Riverside Golf Club,
In our view, even at the summary judgment stage, the plaintiff’s initial burden is to come forward with evidence that gives rise to an inference that the as-yet unexplained employment action in question was taken for a forbidden reason. Very often, the best way to do this will be to use the
McDonnell Douglas
steps, with appropriate modifications depending on the type of case that is presented. In some instances, however, the
McDonnell Douglas
approach may be a poor fit
for the
case, or the plaintiff may wish to introduce other kinds of evidence that also may give rise to an inference of discrimination. In keeping with the Supreme Court’s comments in
Fumco,
a plaintiff should'be free to meet his or her initial burden with this kind of evidence as well, whether we describe it as “mosaic” evidence, see
Troupe,
In a case presenting a complaint about religious discrimination that was quite similar to ours, on which the district court relied, the Tenth Circuit decided to reject the classic McDonnell Douglas formula in favor of the following more flexible approach:
... [I]n order to establish a prima facie case in actions where the plaintiff claims that he was discriminated against because he did not share certain religious beliefs held by his supervisors, we hold that the plaintiff must show (1) that he was subjected to some adverse employment action; (2) that, at the time the employment action was taken, the employee’s job performance was satisfactory; and (3) some additional evidence to support the inference that the *1170 employment actions were taken because of a discriminatory motive based upon the employee’s failure to hold or follow his or her employer’s religious beliefs.
Shapolia v. Los Alamos Nat’l Laboratory,
While Sattar paints an awful picture of Pardesi’s behavior toward him, in which it is clear that Pardesi’s animus was based on Sattar’s failure to follow the religious’ path Pardesi thought he should have,' we agree with the district court that Sattar failed adequately to link his discharge to Pardesi’s religious harassment. We begin with Sat-tar’s strongest piece of evidence, namely, his allegation that Ioriatti specifically told him at the termination meeting that “Mr. Pardesi’s activities have caused this termination; you should have done something about Pardesi’s harassment long ago.” Nonetheless, Ioriat-ti’s opinion does not change the undisputed fact that Pardesi had no direct role in the decisionmaking process that led to Sattar’s termination. It was Yen who made the initial decision to place Sattar in the PIP, and Veechio who structured the PIP for Sattar, who supervised his performance in it, and who made the decision to fire him. Although Sattar has his suspicions, which he details at length, he has not presented any evidence to show how their negative view of his performance was the result of anything Pardesi had said. In short, Ioriatti’s statements do not amount to enough evidence on their own to support an inference that the responsible Motorola officials discharged Sattar because he did not share Pardesi’s Muslim beliefs.
But, Sattar argues, one cannot trust any evidence from Vecchio, Yen, or the other company managers whose evaluations were so devastating to him, because Pardesi poisoned the well for all the others. The district court was willing to assume, and so do we, that when viewed this way the evidence of record was enough to raise an inference that Sattar’s discharge was based on impermissible reasons. See
Shager v. Upjohn Co.,
At this point, we must take into account Motorola’s proffered reasons for the discharge. Motorola argued that he was fired both because his performance was deficient and because he lacked leadership skills. On their face, these easily qualify as legitimate, non-discriminatory reasons; indeed, they are a staple of employer responses in these situations. See,
e.g., Skouby v. Prudential Ins. Co. of America,
He attempts to do so in two ways. First, he points out that he failed only on the subjective part of the PIP, for a lack of “consistency, leadership, initiative, and responsibility skills,” not on the objective tasks he was given. Nevertheless, nothing in Title VII bans outright the use of subjective evaluation criteria. It is true that an employer’s use of subjective criteria may leave it more vulnerable to a finding of discrimination, when a plaintiff can point to some objective evidence indicating that the subjective evaluation is a mask for discrimination. See,
e.g., Giacoletto v. Amax Zinc Co.,
Next, Sattar argues that Motorola’s failure to investigate his repeated claims of harassment by Pardesi indicates that it was tacitly endorsing Pardesi’s religious bigotry, and in turn suggests that the reasons proffered for his termination were pretextual. Again, even if at the summary judgment stage we accepted the first of these propositions, the evidence does not create any link between Motorola’s indifference to his complaints and the reasons it gave for his termination. Vecchio’s affidavit stated that she “received no input” from Pardesi in writing her PIP evaluations and that she discussed neither Sattar’s work nor her evaluation of him with Pardesi. Yen said that he knew that Sattar “was not performing well in Par-desi’s group,” but that he felt he could give Sattar “a fresh start” in his own group. Accepting Sattar’s allegations that Pardesi influenced the design of the PIP, there is still nothing to show that he infected Vecchio’s conclusions at the end of the process. Sattar obviously believes that he might be able to show that Vecchio and Yen were lying about the independence of their evaluations, if he had the chance to put them on the stand. This, however, is not enough to forestall summary judgment.. See
Price v. Rockford,
Ill
Last, Sattar has raised two procedural challenges to the district court’s decision, in which he complains about the court’s rulings on two of his discovery requests. We review this kind of evidentiary matter only for an abuse of discretion, recognizing that “ ‘[district courts have broad discretion in matters related to discovery.’”
Jurcev v. Central Community Hospital,
After that order, Motorola provided Sattar with a hard drive, onto which it transferred the requested e-mail data. When he reviewed it, Sattar and his attorneys claimed that they found evidence that at least some of the data had been altered or modified, and that some of it was incomplete. Sattar then moved again to compel discovery and also for an order to show cause why Motorola should not be held in contempt. The district court found that the motion to compel violated Local Rule 12(K), under which the district court will refuse to hear a motion for production unless it includes a statement (1) that after interactive consultation the parties attempted, but were unable, to resolve the dispute; and (2) that counsel’s attempts to engage in consultation were unsuccessful due to no fault of counsel’s. The court denied the motion for the order to show cause because of the lack of any evidence tending to controvert Motorola’s attorneys’ affidavits swearing that no e-mail message had been altered or deleted.
*1172 Although the district court took a fairly strict approach to Local Rule 12(K), ■ under the circumstances here we do not find this was an abuse of discretion. In context, the court’s order relies on Motorola’s argument that Sattar was trying through this motion to broaden the scope of his discovery of the e-mails. The court acted within the range of reasonable litigation management when it refused to allow Sattar to do so without the necessary predicate dealings with opposing counsel. The court’s ruling on the order to show cause rested on its assessment of the credibility of Motorola’s lawyers. Sattar gives us no reason to second-guess the court’s decision.
We therefore Affirm the judgment of the district court.