Chatman v. Board of Education of the City of Chicago, No. 20-2882 (7th Cir. 2021)Annotate this Case
Chatman, an African-American, worked as an instructor assistant, 1988-1996. From 1997-2009, she worked as a school library assistant. In 2009, the Board of Education informed her that it was eliminating her position. Chatman learned that the Board had replaced Chatman (age 62) with a younger, non-African American employee in the same role. Chatman filed a charge of discrimination with the Illinois Department of Human Rights and the EEOC and then sued in Illinois state court. The Board settled. In addition to a monetary payment, the district was to arrange for interviews for open positions for which Chatman was qualified. Chatman began identifying available positions but did not receive any job offer. She filed a new charge with the EEOC and later filed suit, alleging violations of Title VII’s anti-discrimination and anti-retaliation provisions, and violation of the anti-discrimination provision of the Age Discrimination in Employment Act.
The Seventh Circuit affirmed summary judgment in favor of the Board, finding certain claims barred by the statute of limitations, and, regarding other positions, that Chatman could not establish that she was qualified for the positions, nor could she establish that the Board’s nondiscriminatory reasons for not offering her the positions were pretextual for discrimination. Chatman could not establish that she was denied a job because of her prior protected activity.