Naficy v. IL Dep't of Human Servs., No. 11-2144 (7th Cir. 2012)
Annotate this CaseNaficy began working for IDHS in 1996. According to Naficy, her co-worker and eventual supervisor, Bailey, mocked her accent and suggested that Naficy should not have been promoted because she is Iranian. Naficy filed complaints of discrimination, relating to treatment during a layoff and unfavorable performance evaluations. In 2010, in connection with closure of another facility, IDHS followed provisions of a collective bargaining agreement. Naficy and others received a letter alerting them to the possibility of a layoff and outlining potential bump options. Naficy was reassigned to a part-time position; she returned to her former position with the same schedule and salary two months later. Naficy filed a complaint with the EEOC alleging that the reassignment was discriminatory and retaliatory. She received a right-to-sue letter and filed suit under Title VII, 42 U.S.C. 2000e, and 42 U.S.C. 1981. The district court dismissed the claims, reasoning that as a state agency, IDHS is not a “person” amenable to suit under 42 U.S.C. 1983, and that Naficy had no direct evidence of discrimination by anyone involved in her reassignment, of retaliation, or of a similarly situated IDHS employee who received better treatment than Naficy. The Seventh Circuit affirmed
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