Smith v. Bray, No. 11-1935 (7th Cir., May 24, 2012). The Seventh Circuit held that an individual employee with a retaliatory motive may be individually liable under § 1981 for causing an employer to retaliate against an employee who complained about race harassment.
However, the 7th Cir. held that the District Court did not err in granting motion for summary judgment by defendant-human resources official because the plaintiff failed to present sufficient evidence to establish that his complaints of discrimination motivated defendant to seek plaintiff's termination where plaintiff's only evidence of retaliation consisted of threats of termination made by others, as well as defendant's refusal to return plaintiff's telephone calls or to otherwise speak with her.
Read the case here.
However, the 7th Cir. held that the District Court did not err in granting motion for summary judgment by defendant-human resources official because the plaintiff failed to present sufficient evidence to establish that his complaints of discrimination motivated defendant to seek plaintiff's termination where plaintiff's only evidence of retaliation consisted of threats of termination made by others, as well as defendant's refusal to return plaintiff's telephone calls or to otherwise speak with her.
Read the case here.
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