United States Court of Appeals for the Seventh Circuit
457 F.3d 632 (7th Cir. 2006)
M. Jane Minor (plaintiff) worked for Centocor, Inc. (Centocor) (defendant) as a sales representative. When Antonio Siciliano became Minor’s supervisor at Centocor, Siciliano increased Minor’s workload by approximately 20 to 40 additional hours per week. According to Minor, she began experiencing health problems as a result of these heightened demands. Minor sued Centocor under Title VII of the Civil Rights Act (Title VII), 42 U.S.C. § 2000e et seq., for both age and sex discrimination. The district court held that Minor failed to make a prima facie showing of discrimination, because Centocor took no “adverse employment action” against Minor, who was not fired or demoted. Further, the district court reasoned that the challenged conduct (increased workload as well as supervisor criticism and sharp oversight) comprised routine aspects of employment. It entered summary judgment for Centocor. Minor appealed.
Rule of Law
Holding and Reasoning (Easterbrook, J.)
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