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Wilkerson v. Springfield Public School District No. 186
Citation: 40 F. App'x 260Docket: No. 01-489
Court: Court of Appeals for the Seventh Circuit; July 3, 2002; Federal Appellate Court
Charles Wilkerson, representing himself, appeals a district court's summary judgment against his Title VII claim, which alleges he was forced to resign due to racial discrimination and a hostile work environment. The court found no evidence supporting these claims and affirmed its decision. Wilkerson, an African-American, was hired as a custodian by the Springfield, Illinois, Public School District in 1984 and became head custodian at Washington School in December 1997. He reported no prior incidents of racial discrimination until the hiring of a Caucasian custodian, Kathryn Hoftnan, who allegedly disliked him and sought his position. Witness depositions suggest Hoftnan conspired against Wilkerson, including spreading rumors of theft. Wilkerson recounted an incident in fall 1998 involving inappropriate behavior with Hoftnan and other employees but noted that there were no complaints at the time. He also highlighted an incident involving secret videotaping of an African-American teacher suspected of theft, which he interpreted as evidence of racial bias, although the teacher was ultimately cleared. Subsequently, Hoftnan filed a sexual harassment complaint against Wilkerson, citing the hot dog incident and other inappropriate conduct. Following a meeting with District officials, Wilkerson resigned immediately. He later attempted to rescind his resignation, but was informed it was too late, as the school board had already accepted it, although the acceptance was not confirmed until several days later. The District had no formal policy regarding resignations, and previous cases of rescinded resignations involved employees who were either still employed or on approved leave, unlike Wilkerson, who had ceased work. Wilkerson asserts he provided sufficient evidence of racial discrimination to overcome summary judgment, claiming constructive discharge and a hostile work environment. To establish a prima facie case of race-based discrimination, he must demonstrate membership in a protected class, satisfactory job performance, an adverse employment action, and differential treatment of similarly situated employees outside his class. The focus is on the last two elements. Wilkerson argues he suffered an adverse employment action through constructive discharge, claiming he was effectively forced to resign due to intolerable working conditions following a meeting where he was told he could be fired. However, the court finds that mere communication of potential termination does not constitute constructive discharge, as no evidence was presented that he would have been fired had he not resigned. Additionally, the District was not obligated to allow him to rescind his resignation after it was submitted. Consequently, the court affirms that no adverse employment action occurred, and therefore, Wilkerson was not constructively discharged. Regarding the hostile work environment claim, Wilkerson fails to specify the conduct that rendered his work environment hostile. A hostile work environment requires conduct that is both severe and pervasive enough to alter employment conditions. Wilkerson’s vague assertion does not meet the necessary criteria, and despite the court's liberal interpretation of pro se filings, he does not adequately support his claim. The court thus affirms the dismissal of both claims.