Naficy v. Ill. Dept. of Human Services

Dist. Ct. did not err in granting defendant-employer's motion for summary judgment in Title VII action alleging that defendant reassigned plaintiff to part-time position during shut-down of state facility on basis of her of Iranian nationality and in retaliation for having filed prior complaints alleging discrimination based on her nationality. Record showed that plaintiff was placed into part-time basis due to layoff process that allowed more senior employee to bump plaintiff from her full-time position, and plaintiff failed to present any evidence that her two proposed comparable co-workers were similarly-situated (either in terms of qualifications or in terms of participating in bumping process) with respect to their placement into full-time positions. Moreover, plaintiff failed to establish any causal connection between plaintiff's filing of complaints and her reassignment to part-time position where her 2005 and 2009 complaints occurred five years/nine months prior to said reassignment.