Johnson v. Siemens Building Technologies, Inc.

Summary

Jeffery Johnson sued Siemens Building Technologies, Inc. under Title VII and 42 U.S.C. § 1981, alleging race and sex discrimination and retaliation. The Seventh Circuit affirmed summary judgment for Siemens, holding that Johnson had not shown an adverse employment action, pretext in the employer’s stated reasons for overtime and discipline, or retaliatory motive. The court also upheld dismissal of Johnson’s Illinois-law retaliatory-discharge claim.

Holdings

1. Siemens's failure to provide Johnson with international-shipping training was not a materially adverse change in the terms and conditions of employment and therefore could not support his discrimination claims.
2. Johnson did not show that Siemens's stated reason for requiring overtime—increased business and staffing needs—was pretextual, so summary judgment was proper on his sex-discrimination claim.
3. Johnson failed to show that Siemens's stated reason for suspending and terminating him—his repeated physical and verbal workplace conflicts—was pretextual; temporal proximity alone did not create a triable retaliation issue.
4. The district court reasonably exercised its discretion in declining supplemental jurisdiction over Johnson's Illinois retaliatory-discharge claim after disposing of all federal claims.

Questions Presented

1. Whether Siemens's failure to provide Johnson with international-shipping training constituted an adverse employment action supporting race- or sex-discrimination claims under Title VII and 42 U.S.C. § 1981.
2. Whether Siemens's overtime requirements and temporary accommodation of a female coworker's childcare obligations supported Johnson's sex-discrimination claim or demonstrated that Siemens's stated business justification was pretextual.
3. Whether Johnson presented sufficient evidence that his October 2004 suspension and November 2004 termination were retaliatory for his complaints about race and sex discrimination.
4. Whether the district court properly declined supplemental jurisdiction over Johnson's Illinois retaliatory-discharge claim after dismissing all federal claims.

Disposition

affirmed