Barnes v. Board of Trustees of the University of Illinois, No. 19-1781 (7th Cir. 2020)Annotate this Case
Barnes works in facilities management at UIC, reporting to Donovan. UIC hired Barnes in 2008 as an operating engineer and later promoted him to assistant chief engineer. In 2015, a chief engineer retired. UIC identified 11 candidates, including Barnes, who received one of the top-three exam scores and met the minimum qualifications. Barnes and another candidate were African-American; nine candidates were white. Donavan interviewed the candidates without looking at personnel files or performance evaluations. Donovan selected Civito. Civito and Barnes both have several decades of education and relevant experience. Donovan had interviewed Barnes for 15-30 minutes. Barnes did not bring anything with him to the interview, nor had he been asked to. Donovan interviewed Civito for about 20 minutes. Civito, unprompted, brought written materials including his résumé, a letter of reference, a proposal to solve problems with a UIC building, and training items he developed. Barnes sued, alleging that UIC had a practice of not promoting African-Americans to the chief engineer level. Barnes learned during discovery that in performance reviews by the same supervisor, he had received a higher score than Civito. Donovan claimed that he selected Civito because he came to his interview fully prepared,, articulated the most thoughtful approach to the position and demonstrated a commitment to professional development. The Seventh Circuit affirmed summary judgment for the defendants. Barnes lacked sufficient evidence to support a prima facie case of discrimination or to allow the inference that the legitimate, nondiscriminatory reason offered for hiring Civito was pretextual.