Huff v. Buttigieg, No. 21-1257 (7th Cir. 2022)
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The Seventh Circuit reversed the judgment of the district court granting summary judgment in favor of the Federal Aviation Administration (FAA) and dismissing Plaintiff's claims that the FAA violated Title VII by retaliating against her for filing a formal complaint of religious discrimination, holding that a reasonable juror could conclude that retaliatory animus influenced Defendant's decision-making and proximately caused Plaintiff's termination.
Plaintiff violated the FAA's alcohol and drug policy when she was arrested for an alcohol-related offense. By self-reporting her infraction, Plaintiff avoided disciplinary action if she completed a rehabilitation plan supervised by the FAA. Plaintiff objected on religious reasons to the plan's requirement that she attend Alcoholics Anonymous meetings and complained of religious discrimination, even after the FAA approved her participation in an alternate recovery program. The district court concluded that Plaintiff failed to establish a causal link between the formal complaint and her termination and granted summary judgment to the FAA. The Seventh Circuit reversed, holding that, under the causation standard for federal-sector retaliation claims, a reasonable juror could conclude that retaliatory animus influenced the FAA's decision-making and proximately caused Plaintiff's termination.
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