We review the district court's summary judgment ruling de novo, construing the record in the light most favorable to Mr. Craig. See James v. Hale, 959 F.3d 307, 314 (7th Cir. 2020). To succeed on his Title VII claim relating to his termination, Mr. Craig must show that he engaged in protected activity, that he suffered an adverse employment action, and that a causal connection exists between the two.

Therefore, the Court disregards these statements in the affidavit. See James v. Hale, 959 F.3d 307, 316 (7th Cir. 2020) (“[T]he sham-affidavit rule prohibits a party from submitting an affidavit that contradicts the party's prior deposition or other sworn testimony.”).

Therefore, the Court disregards the statement in the affidavit. See James v. Hale, 959 F.3d 307, 316 (7th Cir. 2020) (“[T]he sham-affidavit rule prohibits a party from submitting an affidavit that contradicts the party's prior deposition or other sworn testimony.”). In his affidavit, the Plaintiff asserts that Heather “was provided a substantial amount of guidance.”

The Court also considers additional factual assertions in Smith's submissions to the extent that he points to evidence in the record or could properly testify about relevant matters. See James v. Hale, 959 F.3d 307, 315 (7th Cir. 2020) (citing Fed.R.Civ.P. 56(c)(4)). That said, a judge must “scrutinize the substance of an affidavit offered in response to a summary-judgment motion to determine whether a reasonable jury could rely on the factual statements it contains, ” id., and “disregard a ‘sham' affidavit.”

James v. Hale, 959 F.3d 307, 316 (7th Cir. 2020) (cleaned up). The sham affidavit rule is narrow.

In the Seventh Circuit, “the sham-affidavit rule prohibits a party from submitting an affidavit that contradicts the party's prior deposition or other sworn testimony.” James v. Hale, 959 F.3d 307, 316 (7th Cir. 2020), citing Dunn v. Menard, Inc., 880 F.3d 899, 910 (7th Cir. 2018). However, “the sham-affidavit rule is narrow and should be applied with caution.” James, 959 F.3d at 317, citing Castro v. DeVry Univ., Inc., 786 F.3d 559, 571 (7th Cir. 2015)(cautioning that the sham-affidavit rule “must be applied with great care ... because summary judgment is not a tool for deciding questions of credibility”).

Every circuit recognizes the “sham affidavit rule.” James v. Hale, 959 F.3d 307, 311 (7th Cir. 2020).

A Fourteenth Amendment claim alleging inadequate medical care is "subject to an objective-unreasonableness standard." James v. Hale, 959 F.3d 307, 318 (7th Cir. 2020). To prevail, the plaintiff must "make a twofold showing." Id.

” Id. Rule 56 thus requires a judge to scrutinize the substance of an affidavit offered in response to a summary-judgment motion to determine whether a reasonable jury could rely on the factual statements it contains. James v. Hale, 959 F.3d 307, 315 (7th Cir. 2020).

Under what is known as the “sham-affidavit rule, ” a party cannot use an affidavit to contradict earlier deposition or sworn testimony for the purpose of manufacturing a dispute of fact to defeat summary judgment. See James v. Hale, 959 F.3d 307, 315-16 (7th Cir. 2020) (citing cases); Adusumilli v. City of Chicago, 164 F.3d 353, 360 (7th Cir. 1998) (quoting Diliberti v. United States, 817 F.2d 1259, 1263 (7th Cir. 1987)) (“A party cannot prevail on a motion for summary judgment by ‘submitting an affidavit containing conclusory allegations which contradict plain admissions in prior deposition or otherwise sworn testimony.'”). When the depositions and affidavit conflict, I must disregard the statements in the affidavit “‘unless it is demonstrable that the statement in the deposition was mistaken.