Barnes-Staples v. Carnahan, No. 22-3275 (7th Cir. 2023)
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In this case heard by the United States Court of Appeals For the Seventh Circuit, Kimberly Barnes-Staples applied for a Real Estate Director position with the General Services Administration (GSA). However, the GSA hired another candidate. Barnes-Staples subsequently sued the GSA, alleging that the interview process discriminated against her because of her race and sex in violation of Title VII of the Civil Rights Act. The district court granted summary judgment in favor of the GSA.
Barnes-Staples argued that the GSA did not follow its internal anti-discrimination procedures, which she claimed allowed the GSA to hire a less qualified candidate. She also contended that she was the superior candidate, so the GSA's assertion that the other candidate was more qualified was pretextual. Furthermore, Barnes-Staples asserted that there was a systemic practice of discrimination against Black candidates and employees within the GSA.
The Appeals Court, however, found that Barnes-Staples was not "clearly better qualified" than the candidate who was hired. It also found no evidence that the GSA created interview questions to favor the other candidate, nor was there evidence that the GSA violated its own guidelines during the interview process. The court also noted that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to support her claim of systemic discrimination.
The Appeals Court affirmed the district court's grant of summary judgment in favor of the GSA. Additionally, it found that Barnes-Staples had waived her sex discrimination claim as she did not properly develop this argument before the district court.
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