Lewis v. Indiana Wesleyan University, No. 21-2327 (7th Cir. 2022)
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Dr. Lewis, a 60-year-old African American woman, alleges that Indiana Wesleyan University discriminated against her when it took away her supervisory responsibilities and ultimately eliminated her position. She brought various claims against the University under 42 U.S.C. 1981, Title VII of the Civil Rights Act of 1964, and the Age Discrimination in Employment Act. The district court granted the university summary judgment on her retaliation claims and concluded that she had waived her age discrimination claim but did not address Dr. Lewis’s race discrimination claim.
The Seventh Circuit affirmed in part, finding that Lewis waived her age discrimination claim, but remanded the race discrimination claim, as requiring factual development. Even when viewed in the light most favorable to Dr. Lewis, the facts do not support a causal connection between her protected activity of complaining about discrimination and an adverse employment action of retaliation.
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