Riley v. Elkhart Cmty. Schs., No. 15-3166 (7th Cir. 2016)Annotate this Case
Elkhart Community Schools (ECS), has employed Riley, an African‐American female, as a teacher since 1980. She has an administrator’s license and is pursuing her doctorate in education. In 2010, she was named the ECS Teacher of the Year. From 2005-2013, Riley unsuccessfully applied for 12 different administrative positions with ECS. Riley filed an Equal Employment Opportunity Commission charge, claiming that race, sex, and age discrimination were the reasons that ECS had not promoted her. The EEOC sent Riley a right to sue letter. Riley filed suit, alleging race, sex, and age discrimination. The district court granted summary judgment for ECS on all counts, dismissing some claims on procedural grounds, and dismissing the remaining claims because Riley had failed to produce sufficient evidence. The Seventh Circuit affirmed. Of the positions for which action was not time-barred, one was given to an African-American woman; Riley did not apply for two; and one position was a lateral move so that Riley did not suffer an adverse employment action. Riley did not produce evidence of pretext with respect to other positions. ECS produced the list of factors that the screening committee considered in recommending candidates.