Introduction

In this nonprecedential disposition, the Seventh Circuit affirmed summary judgment for the City of Chicago Board of Education in a Title VII suit brought by Marvin Bowman, a longtime Chicago Public Schools teacher who identifies as “Bible-Christian.” Bowman alleged religious discrimination, retaliation, and harassment. His claims centered on: (1) delays and alleged interference with his religious-leave requests, (2) assignment to classes with a disproportionate number of students with disabilities compared to the collective bargaining agreement (CBA) cap, and (3) various workplace slights after he complained, including a principal’s religious remark, temperature fluctuations in his classroom, avoidance by the principal, and a colleague’s surreptitious video recording edited in an embarrassing way.

The district court granted summary judgment, finding no triable issue of material fact on any claim. The Seventh Circuit, reviewing de novo and applying post-Muldrow standards for adverse employment action, affirmed. Although the decision is designated “Nonprecedential,” it offers a clear and practical illustration of how courts in the Seventh Circuit are applying the Supreme Court’s recent decision in Muldrow v. City of St. Louis to Title VII discrimination claims, distinguishing between generalized workplace conditions and individualized adverse actions, and reaffirming that retaliation and hostile environment claims impose distinct, often more demanding, thresholds.

Summary of the Opinion

• Religious discrimination: The court held Bowman failed to show an adverse employment action under Title VII’s discrimination framework—even under the lowered “some harm” threshold articulated in Muldrow. The alleged class-composition imbalance was a school-wide issue affecting many teachers and thus not individualized; the record showed his religious leave requests were approved and compensated; and other slights (classroom temperature issues, avoidance, and a colleague’s video) did not affect terms or conditions of employment.
• Retaliation: Because the discrimination claim failed for lack of an adverse action, Bowman could not meet the more demanding “materially adverse” standard applicable to retaliation claims under Burlington Northern and its Seventh Circuit progeny. He also failed to adduce evidence of causation linking protected activity to any materially adverse action.
• Harassment/hostile work environment: The cited incidents were not severe or pervasive as Title VII requires, and the principal’s isolated religious remark—while “troubling”—was insufficiently serious to alter the conditions of employment.
• Disposition: The Seventh Circuit affirmed the district court’s grant of summary judgment on all claims.

Analysis

Precedents Cited and Their Influence

• Muldrow v. City of St. Louis, 601 U.S. 346 (2024): The Supreme Court clarified that a plaintiff alleging discrimination under Title VII need only show “some harm” to an identifiable term, condition, or privilege of employment—rejecting the previously used “significant” or “material” harm formulations for discrimination claims. The Seventh Circuit expressly applied Muldrow’s standard (noting the district court ruled before Muldrow) and emphasized that even under “some harm,” the harm must be tied to the plaintiff’s terms or conditions and, importantly here, must not be merely a generalized workplace condition that is not individualized to the plaintiff.
• Thomas v. JBS Green Bay, Inc., 120 F.4th 1335 (7th Cir. 2024): Post-Muldrow, Thomas provided concrete examples of what can count as adverse actions in discrimination cases (e.g., delaying training, denying vacations, shifting schedules, biased consideration of family circumstances). The court used Thomas to juxtapose Bowman’s allegations—none of which rose to that level and, in key respects, were not individualized.
• Arnold v. United Airlines, Inc., 142 F.4th 460 (7th Cir. 2025): Reinforced that minor changes within the normal scope of employment do not amount to adverse actions, even in the post-Muldrow world. The panel cited Arnold to support characterizing Bowman’s asserted harms (class-composition complications and workplace inconveniences) as neither individualized nor adverse to the terms of employment.
• Mitchell v. Exxon Mobil Corp., 143 F.4th 800 (7th Cir. 2025) and Igasaki v. Illinois Department of Financial & Professional Regulation, 988 F.3d 948 (7th Cir. 2021): Framed the causation inquiry—whether a reasonable factfinder could conclude that the plaintiff’s religion caused the adverse action. With no adverse action and no nexus showing religious animus as the but-for cause, Bowman’s discrimination claim falters under either McDonnell Douglas or the holistic Ortiz approach.
• Ortiz v. Werner Enterprises, Inc., 834 F.3d 760 (7th Cir. 2016): Instructs courts to consider the entire record without formalistic evidentiary pigeonholes. The court noted Bowman lost under both the traditional McDonnell Douglas burden-shifting framework and Ortiz’s holistic view.
• Anderson v. Street, 104 F.4th 646 (7th Cir. 2024): Provided the standard for de novo review at summary judgment and set out elements for retaliation claims. The court leaned on Anderson to frame the analysis for both standard of review and the retaliation prima facie case.
• Estate of Harris v. City of Milwaukee, 141 F.4th 858 (7th Cir. 2025), and Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006): Retaliation claims retain a more demanding standard after Muldrow—the action must be materially adverse and result in “significant” harm, i.e., harm that would dissuade a reasonable worker from engaging in protected activity. Because Bowman could not show even the lower “some harm” standard for discrimination, he necessarily failed the retaliation threshold.
• Vance v. Ball State University, 570 U.S. 421 (2013): Supplies framework for employer liability in harassment cases (supervisor vs. co-worker). While not extensively analyzed here, it anchors the fourth element (basis for employer liability).
• Rongere v. City of Rockford, 99 F.4th 1095 (7th Cir. 2024) and Abrego v. Wilkie, 907 F.3d 1004 (7th Cir. 2018): Illustrate types of conduct insufficient to constitute severe or pervasive harassment (pay complaints, social marginalization, longer hours, excessive monitoring).
• Faragher v. City of Boca Raton, 524 U.S. 775 (1998) and Shanoff v. Illinois Department of Human Services, 258 F.3d 696 (7th Cir. 2001): Faragher stands for the principle that stray or isolated remarks rarely change the terms and conditions of employment; Shanoff contrasts an environment where overt, repeated, and targeted anti-religious statements supported a hostile environment claim. The court used these poles to classify the principal’s remark to Bowman as isolated and insufficiently serious.

Legal Reasoning

1) Discrimination (Title VII § 703(a)(1))

The central inquiry is whether the record could permit a reasonable juror to conclude that Bowman’s religion caused an adverse employment action. Applying Muldrow’s “some harm” threshold, the court held:

• Class composition with disproportionate special-education students: While this arguably made Bowman’s day-to-day tasks more challenging, the record demonstrated the imbalance was school-wide and not unique to Bowman. That matters in two ways. First, a generalized workplace condition, not tailored to or aimed at the plaintiff, does not illustrate the kind of individualized “harm” to a term or condition of employment that Muldrow targets. Second, even if there were harm, the lack of differential treatment undermines causation “because of religion.”
  • Evidence: Bowman’s own spreadsheet reflected that numerous general education classes in core subjects (English, science, social studies) exceeded CBA proportions, contradicting his attempt to limit overages to non-core classes.
  • Manipulation claim: The allegation that officials “manipulated” records to deflate his percentages was unsupported on this record.
• Religious leave requests: The Board’s documentation showed each religious-leave request was approved and paid—some with delays attributable to district audit policies. Delays of this sort, unaccompanied by denial or uncompensated loss, do not constitute adverse actions under Muldrow.
• Other slights (classroom temperature swings, the principal’s avoidance, and a colleague’s edited video): The court characterized these as non-actionable inconveniences or interpersonal frictions that did not alter the terms or conditions of employment. After Muldrow, courts still require harm linked to a work term or condition; indignities without concrete employment effects generally do not suffice.

Even assuming arguendo an adverse action, the Board advanced legitimate, non-discriminatory reasons (e.g., district audit procedures, systemic class-assignment realities), and Bowman failed to show pretext. Under both McDonnell Douglas and Ortiz’s totality-of-evidence approach, the record did not support a causation finding tied to his religion.

2) Retaliation

Retaliation claims require a materially adverse action—a standard more demanding than the “some harm” threshold for discrimination. Because Bowman could not show an adverse action for discrimination, he necessarily failed to establish a materially adverse action for retaliation. Independently, the court found no evidence of a causal nexus between Bowman’s protected activities (grievances and complaints) and any materially adverse consequence.

3) Harassment/Hostile Work Environment

The alleged conduct—delayed leave approvals, disproportionate class assignments, avoidance by the principal, classroom temperature problems, and the edited video—was not severe or pervasive. While the principal’s religiously tinged comment (“You don’t praise the Lord and you got to praise the Lord”) was “troubling,” a single remark of this sort did not transform Bowman’s working conditions and fell far short of the persistent, targeted hostility seen in cases like Shanoff. Thus, no reasonable jury could find that Bowman’s workplace was objectively and subjectively hostile because of his religion.

Impact and Practical Significance

Though nonprecedential, this opinion offers several important practical lessons about the post-Muldrow landscape in Title VII cases within the Seventh Circuit:

• Individualized harm remains essential: Muldrow lowered the bar from “significant” to “some” harm in discrimination cases, but it did not eliminate the need for the harm to be tied to the plaintiff’s terms or conditions of employment and, crucially, to be individualized. Systemwide operational issues or CBA breaches that affect many employees equally generally do not suffice—both because they do not reflect individualized adverse action and because they undermine the inference of discrimination “because of” a protected trait.
• Retaliation standard remains higher than discrimination: Post-Muldrow, plaintiffs should be mindful that retaliation claims still require materially adverse actions producing “significant” harm (in the Burlington Northern sense). A failure to meet the discrimination threshold will frequently doom a parallel retaliation claim unless separate, materially adverse retaliatory acts are proven.
• Stray remarks and minor slights rarely carry harassment claims: Isolated or non-severe incidents—without persistent, targeted, and religion-based hostility—will not meet the “severe or pervasive” standard. Workplace frictions, discomfort, and sporadic indignities remain below the Title VII line.
• Documentation matters: Employers who maintain clear records (e.g., approvals and payments for religious leave; neutral operational explanations like audit requirements) are well positioned to defeat pretext arguments at summary judgment.
• Union/CBA issues versus Title VII: Even where a CBA provision is arguably breached (such as class-composition caps), the appropriate remedy will often be through contractual and union processes rather than Title VII, unless the plaintiff can connect the breach to individualized, religion-based disparate treatment or retaliatory animus.

Complex Concepts Simplified

• Adverse employment action (discrimination): After Muldrow, a plaintiff must show “some harm” to an identifiable term, condition, or privilege of employment—examples include denied training or vacation, or shift transfers with concrete negative effects. The harm need not be “significant,” but it must still be real, tied to work conditions, and (as this case illustrates) individualized.
• Adverse employment action (retaliation): A higher bar. The action must be “materially adverse,” meaning it would dissuade a reasonable worker from making or supporting a charge of discrimination. This is stronger than the “some harm” test used in discrimination claims.
• McDonnell Douglas vs. Ortiz: McDonnell Douglas is a burden-shifting method (prima facie case, employer’s legitimate reason, pretext). Ortiz instructs courts to look holistically at all evidence to decide whether a reasonable jury could find discrimination. Losing under either approach typically ends the claim at summary judgment.
• Hostile work environment: The conduct must be both subjectively and objectively offensive and “severe or pervasive” enough to alter the conditions of employment. Occasional slights or a single non-extreme comment usually won’t qualify.
• De novo review and summary judgment: On appeal, the court re-examines the legal rulings without deference, viewing facts in the light most favorable to the nonmovant (here, Bowman). Summary judgment is proper if no reasonable jury could find for the nonmovant on the evidence presented.
• Nonprecedential disposition: The decision is not binding precedent, but it may be cited under Fed. R. App. P. 32.1. It remains informative about how the Seventh Circuit is applying current Supreme Court and circuit doctrine.

Conclusion and Key Takeaways

• The Seventh Circuit reaffirmed that, even after Muldrow’s “some harm” standard, Title VII discrimination claims require individualized harm to terms or conditions of employment. Broad, systemwide conditions—like school-wide class-composition imbalances—generally do not qualify as adverse actions as to a single plaintiff and do not support an inference of discrimination “because of” religion.
• Retaliation claims remain subject to the more demanding “materially adverse” standard; failure to establish an adverse action for discrimination typically undermines retaliation absent independent materially adverse acts.
• A hostile work environment requires severe or pervasive conduct. Isolated remarks—unless extreme—do not alter the conditions of employment.
• Employers should maintain consistent, documented processes for religious accommodation (such as leave audits) and avoid religiously charged comments in managerial interactions. Plaintiffs should differentiate CBA or systemwide operational issues from individualized, protected-class-based adverse treatment, and marshal evidence of concrete, work-related harms linked to bias or retaliation.

In short, Bowman underscores a practical limit on Muldrow’s lowered adverse-action threshold: “some harm” must still be individualized harm. Without that, and without evidence tying alleged harms to religion or protected activity, Title VII claims will not reach a jury.