Poullard v. McDonald, No. 15-1962 (7th Cir. 2016)
Annotate this CaseSince 2004, Poullard, an African-American man, has worked at the North Chicago Veterans Affairs Medical Center as a training specialist. He received a promotion to the GS‐11 pay grade in 2006, but since then, has received neither a permanent promotion nor a raise. He filed suit, alleging that the refusal to promote him or increase his salary constituted discrimination based on sex and race and that he was subjected to unlawful retaliation and a hostile work environment based on the same lack of pay and recognition, and other incidents. The court rejected the claims on summary judgment, concluding that some claims were time‐barred based on Poullard's failure to timely exhaust administrative remedies under 29 C.F.R. 1614.105(a). On the timely claims, the court held that Poullard had not suffered an adverse employment action and that a reasonable jury could not find that the alleged harassment was sufficiently severe or pervasive to support a hostile work environment claim. The Seventh Circuit affirmed. While it appears that Poullard may not have been managed well or fairly, three arguably race‐tinged remarks, even in combination with the pay disparity and a letter of admonishment, did not show that the alleged harassment was severe or pervasive enough to constitute a hostile work environment.
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