Employer’s Allegedly Prejudicial References Did Not Constitute “Adverse Employment Action”
The issues in this case concerned the post-employment relationship between plaintiff Bernadine Matthews and Wisconsin Energy Corporation Inc. Matthews alleged that Wisconsin Energy breached a settlement agreement and retaliated against her for filing a discrimination lawsuit by giving several prejudicial job references following her departure from the company. The district court held otherwise, granting Wisconsin Energy's motions for summary judgment as to all of Matthews's claims. On appeal, the 7th Circuit reversed the dismissal of Matthew’s contract claim, finding that she had raised genuine issues of material fact as to the intent of the parties under the contract. The circuit court did affirm the dismissal of Matthew’s retaliation claim, finding that none of the allegedly negative references constituted the necessary "adverse employment action" under Title VII.
Matthews v. Wisconsin Energy Corp.
The 7th Circuit Court of Appeals’ jurisdiction includes Illinois, Indiana and Wisconsin.