Bates v. City of Chicago, No. 12-1500 (7th Cir. 2013)
Annotate this CaseBates, a black firefighter, joined the Chicago Fire Department in 1977 and rose through the ranks. In 2000, Fire Commissioner Joyce appointed Bates to one of seven District Chief positions. A District Chief is a member of the personnel management team and holds an at-will position. Bates’s work was well-regarded. Joyce resigned as Fire Commissioner in 2004, and Trotter, also black, became the new Fire Commissioner and chose his own management team; he issued a personnel order that contained eith black and 10 non-black promotions, three black and five non-black demotions, and four lateral reassignments for at-will positions. Bates was demoted to a Deputy District Chief position in Operation Relief, which is a floating assignment. The district court dismissed Bates’s 42 U.S.C. 1981, 1983 claims of racial discrimination. The Seventh Circuit affirmed, rejecting a claim of pretext. Trotter had sufficient experience with Bates and the Chicago Fire Department to support his assertion that Bates’s demeanor and level of enthusiasm were not compatible with his management style.
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