Reives v. Illinois State Police, No. 21-1438 (7th Cir. 2022)
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Reives, who is Black, worked for the Illinois State Police (ISP) from 1989 until he retired in 2018. In 2016, he had been suspended for 60 days for violating internal rules of conduct prohibiting false statements in connection with his employment. The same year, Reives’s supervisors downgraded his ratings on his performance evaluation, leading him to receive a lower ranking on a list of officers certified for promotion. Reives sued, alleging that these two incidents constituted race discrimination under Title VII of the Civil Rights Act of 1964.
The Seventh Circuit affirmed summary judgment for ISP. When a plaintiff alleges that an employer disciplined him more harshly than his comparator, the most relevant similarities are those between the employees’ alleged misconduct, performance standards, and disciplining supervisor. Reives and his comparator, Kim, engaged in different misconduct and were punished for violating different rules. Reives cannot establish a prima facie case of race discrimination under the McDonnell Douglas approach. Reives’s claim also fails under a more straightforward evaluation of the evidence. Reives was still certified for promotion in 2016 and did not explain how his lower ranking affected his promotion prospects.
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