Bless v. Cook County Sheriff’s Office

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s section 1983 and Title VII action alleging that defendant terminated him from his police officer position on account of his white race and Republican Party affiliation. Defendant explained that plaintiff was terminated after it learned that plaintiff was driving while on “Injured on Duty” status, even though he had driving restriction, and because plaintiff was working two separate jobs while obtaining disability benefits under circumstances where plaintiff had provided false statements to defendant’s investigators indicating that he had submitted required requests to work said jobs. Plaintiff failed to provide causal link between his election to political office and his termination, where termination came several months after his election. Moreover, plaintiff failed to present evidence rebutting defendant’s nonpolitical reasons for firing him, and record otherwise showed that defendant’s actions in collecting disability benefits and working unauthorized jobs occurred closer in time to termination than his election. Also, plaintiff failed to present evidence of “background circumstances” that would establish inference that defendant had inclination to discriminate against white employees. Too, plaintiff failed to provide evidence of suitable comparative co-worker who had similar disciplinary history who was treated more favorably.