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Thursday, November 3, 2022

Court Reverses Summary Judgment in Employment Dispute Against City

Recently, the Seventh Circuit Court of Appeals ruled that a former employee could proceed with her employment discrimination claim against a municipal employer. Runkel v. City of Springfield & James O. Langfelder

In 2018, a city purchasing agent announced he was leaving his position. The assistant purchasing agent (Runkel) stated she was interested in the position but was passed over for the role in favor of another employee who at the time worked under Rankel's supervision. At the same time, Rankel was offered a substantial raise to stay in her position as assistant purchasing agent. When she found out she was not being promoted, Rankel was upset and caused a commotion in the office, going so far as to claim the only reason her coworker was hired is because she was Black. The city eventually disciplined Rankel for her remarks, at which time Rankel told the city she would be filing a discrimination complaint. The city then asked Rankel to sign a “last chance” agreement rescinding the pay raise she had been offered and altering the conditions of her work to discourage future outbursts in the workplace.

Rankel eventually left her position with the city and filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC), alleging race discrimination and retaliation for protected activity, which claims ultimately made their way to federal court. The district court ruled in favor of the city, and Rankel appealed.

On appeal, the Seventh Circuit Court of Appeals found that the city should not have been granted summary judgment on Rankel's claims where Rankel had sufficiently established her claims’ prima facie (“on its face”) requirements. In other words, Rankel's complaint that the city had engaged in unlawful race discrimination and retaliation provided the required detailed allegations and her case shold not have been disposed of as a matter of law and need to be fleshed out at trial, where a jury can analyze the city's reasons for termination.

Post Authored by Erin Monforti & Julie Tappendorf, Ancel Glink


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