Lubavitch-Chabad of Illinois, Inc. v. Northwestern University

Dist. Ct. did not err in granting defendant-University’s motion for summary judgment in section 1981 action alleging that defendant improperly disaffiliated plaintiff-Jewish Chabad House from its campus and directed University’s food supplier to terminate its contract with plaintiff’s Rabbi due to defendant’s hostility to Chabad sect of Judaism. Plaintiff’s allegation of religious discrimination is not covered under section 1981, and record otherwise showed that basis for disaffiliation from University was based on complaints of under-aged drinking/alcohol abuse at plaintiff’s House. Fact that certain University staff did not take same measures against other student organizations did not require different result, since said organizations were distinguishable in that they were not managed by adults, and since alleged leniency by University staff occurred at time different decision-maker was in charge.