Woods v. City of Berwyn, No. 13-3766 (7th Cir. 2015)
Annotate this CaseWoods told a coworker at the Berwyn Fire Department that “he wanted to kill somebody, all of them” and that his children were going to “go over there” and “tune them up,” referring to his coworkers and superiors. Chief O’Halloran looked into the statements and eventually recommended termination. A three-member panel for the Board of Fire and Police Commissioners conducted a hearing. Woods was represented by counsel, who gave opening and closing statements, put on witnesses, cross-examined others, made and won objections, and presented exhibits. After the hearing, the Board voted to terminate Woods based largely on the testimony of the co-worker to whom Woods made the statement. Woods filed suit asserting discrimination and unlawful retaliation and attempted to proceed under a “cat’s paw” theory of liability, which applies in employment discrimination cases when a biased subordinate (O’Halloran) who lacks decision-making power uses the formal decision-maker (the Board) as a dupe in a deliberate scheme to trigger a discriminatory employment action. The Seventh Circuit affirmed summary judgment, rejecting Woods’s claims, noting the full and independent evidentiary hearing and the Board’s almost complete reliance on the co-worker’s testimony.
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