Abebe v. Health & Hospital Corp. of Marion County, No. 21-2614 (7th Cir. 2022)
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In 2014, Abebe, a Black woman of Ethiopian origin, began working for Eskenazi Health’s Dental Clinic as a dental assistant. Abebe has had a record of behavior issues throughout her employment; one annual review suggested that she “work on her personal issues that are affecting her interaction with co-workers.” Another review noted that “when she gets upset, her attitude turns to shocking.” Abebe’s 2018 performance review led to Abebe not receiving a merit-based raise, noting three incidents during which Abebe made accusations against co-workers. Abebe contacted the EEOC and alleged for the first time that she had experienced race- and national origin-based discrimination. Abebe claims Eskenazi Health placed her on a Performance Improvement Plan after she spoke to the EEOC. The parties dispute whether the Plan was actually issued or merely discussed. Eskenazi Health decided, a month later, not to impose the Plan.
Abebe sued under Title VII and 42 U.S.C. 1981, alleging discrimination and retaliation. The Seventh Circuit affirmed summary judgment in favor of Eskenazi. Abebe cannot establish a prima facie case of discrimination, nor can she demonstrate that Eskenazi’s reason for the low scores on her performance review was pretextual. Abebe fails to establish a causal connection between her contact with the EEOC and the issuance of the Performance Improvement Plan, nor that issuing the Plan was an adverse employment action.
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