Monroe v. Columbia College Chicago, No. 20-1530 (7th Cir. 2021)Annotate this Case
More than two years after being denied tenure at Columbia College of Chicago, Monroe sued the College, citing Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000d, for being subject to race discrimination in a federally-funded program or activity. The statute does not specify a limitations period.
The Seventh Circuit affirmed the summary judgment rejection of the suit as untimely. Monroe argued that the correct period is the Illinois five-year catch-all limitations period for civil claims, while the College cited the two-year period for personal injuries. The court noted that other Circuits have emphasized that a Title VI claim, although aimed at the discriminatory use of federal funds, is one that ultimately seeks to vindicate personal rights, “closely analogous to [42 U.S.C.] sections 1983 and 1981.” Title VI specifically refers to discrimination against a “person” and should be governed by the limitations period that a state has specified for personal injury claims.