Leitgen v. Franciscan Skemp Healthcare, Inc., 09-1496

Title VII action against former employer

Leitgen v. Franciscan Skemp Healthcare, Inc., 09-1496, concerned a plaintiff's suit against her former employer under Title VII of the Civil Rights Act of 1964 claiming that it retaliated against her by forcing her to resign after she complained that its compensation scheme unlawfully underpaid physicians based on gender.


In affirming the district court's grant of summary judgment in favor of the employer, the court held that to establish a causal connection between plaintiff's allegedly protected conduct and her forced resignation, she had to show that her complaints were "a substantial or motivating factor," and here, the inferences plaintiff attempts to draw from her proffered evidence are too attenuated to survive summary judgment when considered individually or together.

Related Link:

• Read the Seventh Circuit's Full Decision in Leitgen v. Franciscan Skemp Healthcare, Inc., 09-1496