Garofalo v. Village of Hazel Crest

Federal 7th Circuit Court
Civil Court
Employment Discrimination
Case Number: 
Nos. 12-1668 & 12-1681 Cons.
Decision Date: 
June 12, 2014
Federal District: 
N.D. Ill., E. Div.
Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in Title VII action alleging that defendants discriminated against plaintiffs-white police officers for failing to promote them to deputy police chief position on account of their race, when defendants appointed black officer to said position. While police chief occasionally stated to his fellow white officers that newly-elected mayor desired to see more racial diversity in police force, and that they would have no opportunities for promotions because they were of “wrong color,” plaintiffs failed to present evidence that they had chance at instant promotion, where both plaintiffs failed to present evidence that their perceived shortcomings for said position, i.e., lack of leadership skills and decision-making abilities, as well as having volatile and unstable personality, did not play role in decision not to promote them to said position.