Scaife v. United States Department of Veterans Affairs, No. 21-1152 (7th Cir. 2022)
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In 2010, Scaife, an African-American woman, began working as a specialist classifying VA jobs. Scaife received “Outstanding” or “Excellent” ratings on her annual performance reviews. After a few years, Earp, a white male, became Scaife’s immediate supervisor. Scaife claims he mistreated women employees. In 2016, Earp told Scaife and another black female that he wanted them to classify positions higher if told to do so. When Scaife inquired whether doing so would violate regulations, Earp became “aggressive.” Scaife inquired about the process for addressing a hostile work environment and sent text messages to Earp’s supervisor. After an incident during which another white male referred to Scaife as a "N-----," Scaife filed EEO charges. Scaife received a formal counseling email. Scaife later accepted an offer for the same classifier position at a California VA center, which allowed her to work remotely.
Scaife sued under Title VII, claiming a race and gender-based hostile work environment, retaliation, and constructive discharge. The Seventh Circuit affirmed summary judgment in favor of the VA. Given the totality of circumstances, Scaife failed to show that the one-time use of the N-word outside of her presence established a hostile work environment based on race. Scaife failed to show harassment based on gender, that the alleged conduct was severe or pervasive, or that she endured a hostile work environment based on both race and gender. Absent evidence that she suffered an adverse action, Scaife cannot establish retaliation.
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