Dist. Ct. did not err in granting defendant-University’s motion for summary judgment in plaintiff-professor’s Title VII and Title IX claims alleging that she was retaliated against after forwarding student complaint of sexual harassment and after filing EEOC complaint. Plaintiff’s alleged adverse acts with respect to Title IX claim, i.e., staff criticism of plaintiff for reporting of student complaint and failure to support her cybersecurity curriculum initiative were not sufficiently material to support such claim, as said alleged acts were either not supported by record or did not have employment consequence. Moreover, while defendant’s “letter of direction” and letter to chancellor seeking formal reprimand of plaintiff did qualify as material adverse acts for purposes of plaintiff’s Title VII claim, plaintiff failed to show that either adverse act was linked to her filing of EEOC charge, where said letters were sent six months after filing of EEOC charge. Ct. further noted that: (1) plaintiff failed to present evidence that contested accuracy of allegations against her in either letter; and (2) defendant treated plaintiff positively during relevant time period by granting her tenure and seeking upward salary adjustment.
Federal 7th Circuit Court
Civil Court
Retaliation