Vance v. Ball State Univ., No. 08-3568 (7th Cir. 2011)Annotate this Case
The employee began work at the university in 1989 and was the only African-American working in her department when racially charged discord erupted. In 2005, she began filing complaints about her coworkers’ offensive conduct, which included the use of racial epithets, references to the Ku Klux Klan, veiled threats of physical harm, and other unpleasant conduct. In 2006 she filed two complaints with the EEOC for race discrimination and, later, retaliation. After getting her right-to-sue letter, she filed in a range of federal and state discrimination claims. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed, holding that she did not establish employer liability on the hostile work environment claim or put forth sufficient facts to support her retaliation claim under Title VII (42 U.S.C. 2000e). The university promptly investigated each complaint and the employee, who was promoted and got a raise, did not suffer a materially adverse employment action.