Bates v. City of Chicago

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in Title VII action alleging that defendant demoted plaintiff-firefighter from his District Chief position to Deputy District Chief position on account of his race. Record showed that decision-maker, as well as plaintiff’s replacement shared plaintiff’s African-American race, and plaintiff failed to present evidence that he was treated worse than similarly-situated co-workers, where five of eight relevant demotions were for non-African-Americans, and where record supported defendant’s claim that plaintiff did not share similar work history with others, who were given promotions. Plaintiff also failed to present evidence that defendant’s explanation for his demotion, i.e., that plaintiff did not share decision-maker’s management style, was pretextual.