This Littler Lightbulb highlights some of the more significant employment and labor law developments in the federal courts of appeal in the last month.

Seventh Circuit Affirms Summary Judgment for University in Professor’s Race Bias Suit

Saud v. DePaul University, 154 F.4th 563 (7th Cir. 2025), involved a former university professor’s claim of race discrimination in violation of 42 U.S.C. § 1981 based on the university’s decisions (1) not to rehire him as an adjunct professor and (2) deeming him ineligible for future employment. In response, the university argued it based its decisions on (1) its investigation of allegations in a separate lawsuit filed by one of the professor’s students claiming he improperly induced her to have sexual relations, (2) two additional reports of potential misconduct, (3) low projected enrollment in the professor’s courses, and (4) the plaintiff’s request for a higher salary than the department had authorized for the adjunct position. The district court granted the university’s motion for summary judgment, and the plaintiff appealed.

On appeal, the Seventh Circuit noted, “[t]he same legal standard applies to claims of racial discrimination under Title VII [and] Section[] 1981 ….” Under both statutes, the plaintiff must prove, among other things, they were treated less favorably than similarly situated employees who were not members of the protected class, and the employer’s explanation for its decision was pretextual.

As to the decision not to...

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