Insufficient Evidence Of Retaliatory Animus In Denial of Promotion

Linette Metzger, a civilian or non-sworn employee of the Illinois State Police (“ISP”), brought suit alleging that ISP denied her promotions in violation of Title VII by retaliating against her for having previously filed a sex discrimination suit against it. The district court granted summary judgment in favor of ISP. On appeal, the 7th Circuit affirmed, concluding that: 1) Metzger did not show that ISP retaliated against her by denying her a position upgrade because there was no evidence that the decision was influenced in any way by the retaliatory animus a supervisor allegedly harbored against her; and 2) Metzger did not produce sufficient evidence to create a genuine issue of material fact as to whether retaliation, rather than the requirement that a position be filled by a sworn officer, was the reason for one employment decision.

Metzger v. Illinois State Police

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The 7th Circuit Court of Appeals’ jurisdiction includes Illinois, Indiana and Wisconsin.