CASE NAME

Vavra v. Honeywell

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Overview

Appellant, a former employee of Defendant, alleged that he was fired for voicing objections to Defendant's implicit bias training initiative.

Details

The district court granted summary judgment to Defendant. The court held that there was no evidence that the training was racially discriminatory, and further held that Plaintiff's refusal to take the training was not protected activity under Title VII.

In addition, the court held that although Plaintiff engaged in protected activity by writing complaint emails, Plaintiff pointed to no evidence that his employment was terminated for engaging in such protected activity.

Plaintiff appealed to the Seventh Circuit Court of Appeals. The appeals court dismissed the appeal in July 2024, finding that Appellant's retaliation claim was "meritless." The court held that Appellant's opposition to the DEI training was not protected activity, and that even if some of his complaints were protected activity, he did not demonstrate a causal connection between the complaints and his termination.

Court

Seventh Circuit Court of Appeals

Status

Filed September 20, 2023 | Decided

Relevant Law

Title VIIState law

Illinois Human Rights Act