Lathan v. State of Illinois Department of Public Health

CourtDistrict Court, C.D. Illinois
DecidedSeptember 8, 2025
Docket3:21-cv-03031
StatusUnknown

This text of Lathan v. State of Illinois Department of Public Health (Lathan v. State of Illinois Department of Public Health) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lathan v. State of Illinois Department of Public Health, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

GINA LATHAN, ) ) Plaintiff, ) ) v. ) 21-cv-3031-DJQ ) STATE OF ILLINOIS DEPARTMENT ) OF PUBLIC HEALTH, ) ) Defendant. )

OPINION Before the Court is Defendant State of Illinois Department of Public Health’s (“IDPH”) Motion for Summary Judgment. (Doc. 48). Plaintiff Gina Lathan (“Lathan”) alleges racial discrimination but concedes that the non-renewal of her contract and retaliation claims fail as a matter of law. Thus, the only issues before the Court are whether Lathan has sufficient evidence that would permit a reasonable factfinder to conclude: (1) she suffered an adverse employment action because of her race or (2) she was subjected to a hostile work environment because of her race. The Court concludes no reasonable jury could find either. Therefore, IDHP’s Motion for Summary Judgment (Doc. 48) is GRANTED. I. BACKGROUND A. Facts On February 1, 2017, Lathan, who is African-American/Black, was hired to a four- year term as IDPH’s Immunization Section Chief, in the Division of Infectious Disease. The Division of Infectious Disease was part of the Office of Health Protection. Lathan held the position until January of 2021 when her contract expired. Except from when she

started in 2017 until August of 2018 and again from January to March of 2020, Lathan was directly supervised by Heidi Clark, who was Chief of the Division of Infectious Disease. Besides Lathan, Clark supervised three other Section Chiefs: Eduardo Alvarez, Danny Brinkshavana, and Judy Kauerauf, none of whom are African-American/Black. From February 6, 2017, until May 31, 2020, Molly Lamb was the Deputy Director of the Office of Health Protection. Lamb interviewed Lathan for her position. When the

position of Chief of the Division of Infectious Disease was vacant, or when Clark was on prolonged leave, Lamb directly supervised Lathan. Lathan asserts that Lamb was the primary person who harassed her because of her race. Lathan alleges the racial discrimination and harassment occurred between 2017 and February 4, 2020. B. Allegations

Lathan alleges she was subjected to a hostile work environment and to different terms and conditions of employment as compared to her white colleagues. (Doc. 54, pp. 19–21; 24). Her primary assertion is she was given unequal job assignments because of her race and others similarly situated were treated better. Specifically, she alleges nine incidents: (1) being assigned to complete a Court of Claims backlog that had been ignored

by two white colleagues. Because Lathan did not timely complete the backlog, she was counseled; (2) Immunization Section grant funds being misdirected and given to the Communicable Disease Section; (3) one of her subordinate employees, Melissa Turley, refusing to complete her duties on an audit, and Lamb not allowing Lathan to discipline Turley but instead assigning the audit duties to Lathan; (4) Lamb requiring Lathan, during work hours, to assist Lamb completing unrelated school assignments; (5) Lamb

placing a memo in Lathan’s “supervisory file” falsely accusing Lathan of not using the grant management process properly and then not allowing Lathan to challenge it; (6) forcing Lathan to move her staff to a location with inadequate space which resulted in the Section not being able to hire additional staff because of the lack of space; (7) Lathan having to utilize inmates to move her Section to a new location, whereas other Section managers were allowed to use professional movers; (8) being forced to work at a

warehouse to inventory and dispose or transfer items when other Section heads were not required to do this type of physical labor; and (9) being omitted from a scheduled meeting to discuss grant submissions for her Section when at least one other Section Chief, Judy Kauerauf, was invited to the meeting. (Doc. 54, pp. 19–21). C. IDPH’s Response IDPH asserts that many of the alleged incidents either did not occur, are

otherwise explainable, or are otherwise immaterial. Primarily, IDPH asserts that none of the nine alleged incidents altered the terms or conditions of Lathan’s employment and that there is no evidence that any of the alleged acts or omissions were directed towards Lathan because of her race. It also argues that the incidents, considered together, could not have created a hostile work environment as a

matter of law. II. LEGAL STANDARD “The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a

matter of law.” Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986). “Material facts are those that might affect the outcome of the suit, and a factual dispute is genuine if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Biggs v. Chic. Bd. of Educ., 82 F.4th 554, 559 (7th Cir. 2023) (internal quotation marks and citation omitted). In ruling on a motion for summary judgment, a district court “has one task and one task only: to decide, based on the evidence of

record, whether there is any material dispute of fact that requires a trial.” Waldridge v. Am. Hoechst Corp., 24 F.3d 918, 920 (7th Cir. 1994). III. ANALYSIS Because retaliation and not having her contract renewed have been conceded, the remaining issues are whether Lathan suffered an adverse employment action

because of her race or was subjected to a hostile work environment because of her race. The Court will first address adverse employment actions because of her race. Lathan argues that summary judgment is inappropriate both pursuant to the holistic approach and the McDonnell Douglas analysis. Under the holistic analysis, courts must evaluate the evidence as a whole. Ortiz v.

Werner Enterprises, Inc., 834 F.3d 760, 766 (7th Cir. 2019). The test is “simply whether the evidence would permit a reasonable factfinder to conclude that the plaintiff’s race, ethnicity, sex, religion, or other proscribed factor caused the discharge or other adverse employment action.” Id. at 765. See also Vega v. Chicago Park Dist., 954 F.3d 996, 1004 (7th Cir. 2020) (“What matters is whether she presented enough evidence to allow the jury to find in her favor.”).

Under the framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802– 03 (1973), to make a prima facie case of race discrimination, Lathan must show that she (1) belongs to a protected class, (2) was qualified for the job, (3) suffered an adverse employment action, and (4) was treated less favorably than similarly situated employees outside of her protected class. Igasaki v. Illinois Dep’t of Fin. and Pro. Regul., 988 F.3d 948, 957 (7th Cir. 2021). Most plaintiffs find meeting “the prima facie burden is ‘not onerous.’”

Ames v. Ohio Dep’t of Youth Servs., 145 S. Ct. 1540, 1545 (2025) (quoting Texas Dep’t of Cmty. Affs. v. Burdine, 450 U.S. 248, 253 (1981)). The Supreme Court has repeatedly explained that the “precise requirements of a prima facie case can vary depending on the context and were ‘never intended to be rigid, mechanized, or ritualistic.’” Id. at 1546 (quoting Swierkiewicz v. Sorema N. A., 534 U.S. 506, 512 (2002)).

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