Morgan v. SVT, LLC

226 Citing cases

  1. Hatcher v. Bd. of Trs. S. Ill. Univ.

    Case No. 13-CV-407-NJR-SCW (S.D. Ill. Feb. 18, 2015)

    In order to succeed in a Title VII lawsuit for gender discrimination, a plaintiff must show that her employer took an adverse employment action against her because she is a woman. See Morgan v. SVT, LLC, 724 F.3d 990, 995 (7th Cir. 2013). When the adverse employment action is the denial of tenure at the college or university level, "practical considerations make [the] challenge an uphill battle."

  2. Copeling v. Ill. State Toll Highway Auth.

    12 C 10316 (N.D. Ill. Jul. 24, 2014)

    As noted above, Copeling's sole remaining claim alleged racially disparate treatment under Title VII and § 1981. Title VII and § 1981 claims are analyzed under the same framework, so the court will simplify by referring only to Title VII doctrine and precedents. See Morgan v. SVT, LLC, 724 F.3d 990, 995 (7th Cir. 2013); Smith v. Bray, 681 F.3d 888, 89596 & n.2 (7th Cir. 2012); Egonmwan v. Cook Cnty. Sheriff's Dep't, 602 F.3d 845, 850 n.7 (7th Cir. 2010) ("The same requirements for proving discrimination apply to claims under Title VII, § 1981, and § 1983."). Copeling may defeat summary judgment under the direct and indirect methods of proof.

  3. Finke v. Trs. of Purdue Univ.

    Civil No. 1:12-CV-124-JD (N.D. Ind. Jun. 30, 2014)   Cited 2 times

    If Finke can make that showing, then the burden shifts to the defendants to counter with legitimate, non-discriminatory reasons for their actions, and if they can do so, then the burden shifts back to Finke to show that the proffered reasons are a pretext for discrimination. Id.A discussion of just what Finke bears the burden of showing to defeat a motion for summary judgment is appropriate here. Finke argues that the Seventh Circuit has somehow (to her benefit) eliminated the distinction between the direct and indirect methods and "espoused" a "new standard" in Morgan v. SVT, LLC, 724 F.3d 990 (7th Cir. 2013) [DE 61 at 8]. This is incorrect: as the defendants properly argue, though the Morgan court decried the sometimes confusing distinctions and rigid formulations of the direct and indirect methods of proof, it was clear that "[t]he real distinction between these two methods . . . is not whether one relies solely on 'direct' evidence (in the sense of a smoking gun) and the other relies on circumstantial evidence."

  4. Goodall v. Legum & Norman

    13 C 1474 (N.D. Ill. Jun. 18, 2014)

    Title VII and § 1981 claims are analyzed under the same framework, so the court will simplify by referring only to Title VII doctrine and precedents. See Morgan v. SVT, LLC, 724 F.3d 990, 995 (7th Cir. 2013); Smith v. Bray, 681 F.3d 888, 895-96 & n.2 (7th Cir. 2012); Egonmwan v. Cook Cnty. Sheriff's Dep't, 602 F.3d 845, 850 n.7 (7th Cir. 2010) ("The same requirements for proving discrimination apply to claims under Title VII, § 1981, and § 1983."). To defeat summary judgment, Goodall may proceed under either the direct or indirect methods of proof.

  5. Griffin v. Evanston/Skokie Consol. Sch. Dist. 65

    12 C 9828 (N.D. Ill. Jun. 10, 2014)   Cited 1 times

    Employment-related race discrimination claims under § 1983 and § 1981 are analyzed under the Title VII framework, so the court will simplify by referring only to Title VII doctrine and precedents. See Morgan v. SVT, LLC, 724 F.3d 990, 995 (7th Cir. 2013); Smith v. Bray, 681 F.3d 888, 895-96 & n.2 (7th Cir. 2012); Egonmwan v. Cook Cnty. Sheriff's Dep't, 602 F.3d 845, 850 n.7 (7th Cir. 2010) ("The same requirements for proving discrimination apply to claims under Title VII, § 1981, and § 1983."). A Title VII race discrimination plaintiff may seek to defeat summary judgment under the direct and indirect methods of proof.

  6. Arce v. Chi. Transit Auth.

    193 F. Supp. 3d 875 (N.D. Ill. 2016)   Cited 13 times
    Surveying case law

    The appropriate focus under the direct method "is not whether the evidence offered is direct or circumstantial but rather whether the evidence points directly to a discriminatory reason for the employer's action." Atanus v. Perry , 520 F.3d 662, 671 (7th Cir.2008) (internal quotation marks omitted); see alsoMorgan v. SVT, LLC , 724 F.3d 990, 997 (7th Cir.2013) ( "The plaintiff's task in opposing a motion for summary judgment is straightforward: he must produce enough evidence, whether direct or circumstantial, to permit the trier of fact to find that his employer took an adverse action against him because of his race."); Everett v. Cook Cnty. , 655 F.3d 723, 729 (7th Cir.2011) ; Davis v. Time Warner Cable of Se. Wis., L.P. , 651 F.3d 664, 672 (7th Cir.2011). "Direct evidence is evidence that, if believed by the trier of fact, would prove discriminatory conduct on the part of the employer without reliance on inference or presumption.

  7. Hillman v. Costco Wholesale Corp.

    12 C 6012 (N.D. Ill. Jul. 14, 2014)   Cited 4 times

    Because Hillman does not identify which method he is pursuing, the court will consider both. See Morgan v. SVT, LLC, 724 F.3d 990, 997 (7th Cir. 2013). Hillman cannot meet his burden under the direct method.

  8. Yuhe Diamba Wembi v. Metro Air Serv.

    195 F. Supp. 3d 957 (N.D. Ill. 2016)   Cited 2 times

    The appropriate focus under the direct method "is not whether the evidence offered is direct or circumstantial but rather whether the evidence points directly to a discriminatory reason for the employer's action." Atanus v. Perry , 520 F.3d 662, 671 (7th Cir.2008) (internal quotation marks omitted); see alsoMorgan v. SVT, LLC , 724 F.3d 990, 997 (7th Cir.2013) ( "The plaintiff's task in opposing a motion for summary judgment is straightforward: he must produce enough evidence, whether direct or circumstantial, to permit the trier of fact to find that his employer took an adverse action against him because of his race."); Everett v. Cook Cnty. , 655 F.3d 723, 729 (7th Cir.2011) ; Davis v. Time Warner Cable of Se. Wis., L.P. , 651 F.3d 664, 672 (7th Cir.2011)."Direct evidence is evidence that, if believed by the trier of fact, would prove discriminatory conduct on the part of the employer without reliance on inference or presumption. In short, [d]irect evidence essentially requires an admission by the decision-maker that his actions were based upon the prohibited animus.

  9. Bridgeforth v. Cook Cnty.

    14 C 4443 (N.D. Ill. Oct. 13, 2015)   Cited 1 times

    The appropriate focus under the direct method "is not whether the evidence offered is direct or circumstantial but rather whether the evidence points directly to a discriminatory reason for the employer's action." Atanus v. Perry, 520 F.3d 662, 671 (7th Cir. 2008) (internal quotation marks omitted); see also Morgan v. SVT, LLC, 724 F.3d 990, 997 (7th Cir. 2013) ("The plaintiff's task in opposing a motion for summary judgment is straightforward: he must produce enough evidence, whether direct or circumstantial, to permit the trier of fact to find that his employer took an adverse action against him because of his race."); Everett v. Cook Cnty., 655 F.3d 723, 729 (7th Cir. 2011); Davis v. Time Warner Cable of Se. Wis., L.P., 651 F.3d 664, 672 (7th Cir. 2011). "Direct evidence is evidence that, if believed by the trier of fact, would prove discriminatory conduct on the part of the employer without reliance on inference or presumption.

  10. Anderson v. Dep't of Veterans Affairs

    No. 1:14-cv-00129-SLC (N.D. Ind. Mar. 30, 2017)

    "'Direct' proof includes both evidence explicitly linking an adverse employment action to an employer's discriminatory animus and circumstantial evidence that would permit the trier of fact to infer that discrimination motivated the adverse action." Morgan v. SVT, LLC, 724 F.3d 990, 995 (7th Cir. 2013) (citations omitted). While the Seventh Circuit has used the "metaphor of a mosaic whose individual tiles add up to a complete picture" in order to illustrate the concept of the circumstantial evidence that must be presented to satisfy the direct method of proof, it has made clear that there is no "esoteric 'mosaic test' or theory.