Withdrawing an EEO Complaint Does Not Negate Protected Activity, but Temporal Proximity Alone Will Not Prove Title VII Retaliation Absent Corroboration When the Employer Honestly Relies on Admitted Medication Errors
I. Introduction
In Hakeem Abayomi v. Douglas A. Collins, the Seventh Circuit affirmed summary judgment for the
Department of Veterans Affairs (“VA”) on a former clinical pharmacist’s Title VII claims for
race discrimination and retaliation. Abayomi, the only African American pharmacist at the Hines, Illinois
facility, alleged that he was terminated because of his race and in retaliation for filing an internal EEO complaint
against his supervisor.
The appeal centered on two recurring Title VII questions: (1) whether the VA’s stated reason for discharge—serious
medication errors—was pretext masking discriminatory animus; and (2) whether Abayomi could show but-for
causation for retaliation where he filed (and then withdrew) an EEO complaint shortly before a disciplinary inquiry
and termination near the end of a probationary period.
II. Summary of the Opinion
The court held that Abayomi failed to produce evidence from which a reasonable jury could find that the VA’s reason
for firing him was pretextual. His own admissions during the VA’s “Weingarten investigation” that he committed
multiple medication-related mistakes substantially undercut any inference that the termination rationale was a lie.
Comparator evidence also failed because alleged comparators were unsupported in the record, and the most developed
comparator differed materially (different decisionmaker, different probationary status, different investigative
posture, and contested allegations).
On retaliation, the court rejected the VA’s suggestion that Abayomi’s voluntary withdrawal of his EEO complaint
negated protected activity. However, it concluded that Abayomi lacked evidence of but-for causation: timing
alone, without corroborating evidence of retaliatory motive, could not overcome the VA’s contemporaneous reliance on
reported medication errors—three of which Abayomi admitted.
III. Analysis
A. Precedents Cited
1. Summary judgment posture and evidentiary burdens
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Scaife v. United States Dep't of Veterans Affs.: The court reiterated that facts are viewed in the
light most favorable to the non-movant at summary judgment, framing how the record is read but not permitting
conjecture to replace evidence.
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Adebiyi v. S. Suburban Coll. and Johnson v. Accenture LLP: These cases grounded the
de novo standard of review and the requirement that the non-movant identify specific evidence creating a genuine
dispute for trial.
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Metzler v. Loyola Univ. Chicago: The court invoked the principle that judges cannot “fill in
evidentiary holes with speculation,” a key constraint on Abayomi’s comparator and inference-based arguments.
2. Discrimination framework, “the sole question,” and pretext
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McDonnell Douglas Corp. v. Green and Lohmeier v. Gottlieb Mem'l Hosp.: The opinion
used the familiar burden-shifting structure for circumstantial discrimination claims, including the role of
comparators and the subsequent pretext inquiry once an employer provides a nondiscriminatory reason.
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Ortiz v. Werner Enters., Inc.: The court emphasized that all evidence must be considered “as a
whole” and refocused the analysis on the “sole question that matters”: whether the plaintiff would have kept his
job if everything were the same but for his protected trait.
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Vassileva v. City of Chicago (quoting Benuzzi v. Bd. of Educ. of City of Chicago):
These cases supported the court’s decision to move directly to pretext where the employer has articulated a
nondiscriminatory explanation, recognizing overlap between the prima facie and pretext inquiries.
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Sweatt v. Union Pac. R.R. Co. and Harper v. C.R. England, Inc.: The court applied
the Seventh Circuit’s strict conception of pretext—“a dishonest explanation, a lie”—and the “honest belief” rule:
the question is not whether the decision was correct or fair, but whether the employer honestly believed the stated
reason.
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Cunningham v. Austin: Reinforced that federal courts are not “superpersonnel department[s]” that
re-weigh performance judgments, a direct answer to Abayomi’s attempts to relitigate the accuracy and gravity of the
medication errors.
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Tyburski v. City of Chicago (quoting Benuzzi v. Bd. of Educ. of City of Chicago):
The court stressed that demonstrating inaccuracy is not enough; the plaintiff must identify circumstances
supporting an inference of unlawful motive.
3. Comparator evidence and “similarly situated” limits
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Napier v. Orchard Sch. Found. (quoting Khowaja v. Sessions) and
Coleman v. Donahoe: The opinion treated comparator evidence as relevant to pretext and reiterated
that the “similarly situated” inquiry aims to eliminate alternative explanations (role, history, standards,
decisionmakers) to isolate discriminatory animus.
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Schandelmeier-Bartels v. Chi. Park Dist.: Used to identify the proper “decisionmaker” for
comparator purposes, which mattered because the relevant decisionmaker (Lynx) was not present for the later
comparator employee.
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Steinhauer v. DeGolier: Supported the proposition that probationary status can be a material
difference defeating comparator similarity.
4. Retaliation doctrine: protected activity, material adversity, and but-for causation
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Abrego v. Wilkie: Supplied the Seventh Circuit’s elements for Title VII retaliation claims,
including but-for causation.
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Xiong v. Bd. of Regents of the Univ. of Wis. Sys.: Reinforced but-for causation while clarifying
that protected activity need not be the only cause; it must be the cause without which the adverse action would not
have occurred.
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Thompson v. N. Am. Stainless, LP and Burlington N. & Santa Fe Ry. Co. v. White:
These Supreme Court cases supported the panel’s conclusion that filing a charge is protected activity and that the
anti-retaliation provision is construed broadly to deter employer conduct that would dissuade reasonable workers
from complaining.
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Castro v. DeVry Univ., Inc.: Used for two propositions: (1) a complaint qualifies as protected
activity if sincerely and reasonably believed; and (2) no bright-line temporal proximity rule—timing can support
causation when combined with corroborating evidence of retaliatory motive.
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Alley v. Penguin Random House and Kidwell v. Eisenhauer: Cited for the types of
circumstantial evidence relevant to causation (ambiguous statements, differential treatment, pretext, suspicious
timing).
5. Union representation and investigative interviews
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N.L.R.B. v. J. Weingarten, Inc.: Provided the foundation for “Weingarten investigations,” i.e.,
investigatory interviews where unionized employees have a right to representation when questioning may lead to
discipline.
6. Waiver and undeveloped theories
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Matthews v. Waukesha Cnty.: Mentioned as the canonical “cat’s paw” authority, but the court did not
reach the theory.
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Rock Hemp Corp. v. Dunn and Anderson v. Donahoe: The panel held that perfunctory,
undeveloped arguments and arguments not presented at summary judgment are waived—used to reject any belated “cat’s
paw” framing based on the supervisor’s alleged bias.
B. Legal Reasoning
1. Discrimination: pretext could not be shown where admissions supported the stated reason
The VA articulated a legitimate, nondiscriminatory rationale: careless work performance and failure to follow policy
tied to medication errors, specifically the April 8 heparin dispensing error and April 13 labeling error. The panel
treated the case as turning on pretext (consistent with Vassileva v. City of Chicago and
Ortiz v. Werner Enters., Inc.), asking whether the VA’s explanation was a lie.
Abayomi attacked the accuracy and seriousness of the Weingarten findings, but the court applied the “honest belief”
framework from Harper v. C.R. England, Inc.: even if the employer is mistaken or harsh, Title VII is
violated only if the stated reason is dishonest. The court found that Abayomi’s own statements during the
investigation—admitting three errors and partly contesting the fourth—made it unreasonable to infer fabrication.
His admissions that he was “rushing” functioned as direct support for the VA’s “careless work performance”
characterization.
2. Discrimination: comparator theory failed on missing proof and meaningful differences
Abayomi attempted to show pretext by selective enforcement, invoking four pharmacists. The court rejected three
comparators due to lack of record evidence of their errors. As to Patrick Hammond, the court explained that the
“similarly situated” requirement from Coleman v. Donahoe was not met for multiple independent
reasons:
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Different decisionmaker: Lynx was the likely final decisionmaker for Abayomi’s termination, but
Lynx had left by Hammond’s employment (Schandelmeier-Bartels v. Chi. Park Dist.).
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Different probationary status: Hammond was not probationary at the relevant time, a recognized
differentiator (Steinhauer v. DeGolier).
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Different evidentiary posture: Hammond contested allegations and was cleared of most, whereas
Abayomi admitted three errors.
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Speculative comparison of investigative mechanisms: Abayomi offered no evidence that a Weingarten
interview is more punitive than an OMI investigation; without such evidence, the court would not speculate
(Metzler v. Loyola Univ. Chicago).
3. Retaliation: withdrawal of the EEO complaint did not erase protected activity
A significant doctrinal clarification in the opinion is its rejection of the VA’s argument that Abayomi could not be
retaliated against because he withdrew his EEO complaint before termination. Relying on
Thompson v. N. Am. Stainless, LP and the anti-deterrence principle from
Burlington N. & Santa Fe Ry. Co. v. White, the court held the “filing of a charge” is what matters
and warned that adopting the VA’s theory would create a perverse incentive to pressure withdrawals. The panel also
reaffirmed that protected activity does not require a meritorious complaint; it suffices that it is “sincerely and
reasonably believed” (Castro v. DeVry Univ., Inc.).
4. Retaliation: causation failed despite close timing because corroboration was absent
The panel then applied the but-for causation requirement from Abrego v. Wilkie and
Xiong v. Bd. of Regents of the Univ. of Wis. Sys.. Although the timeline was tight (complaint filed
March 7; medication error reports starting April 8; Weingarten April 19; termination April 29), the court emphasized
that temporal proximity is not enough when the record contains a concrete, non-retaliatory basis for discharge
supported by the employee’s admissions.
Consistent with Castro v. DeVry Univ., Inc. and Coleman v. Donahoe, the court
acknowledged it has “rejected any bright-line rule” and that weeks or months can be probative when combined with
corroborating evidence of retaliatory motive. But Abayomi offered none beyond timing and his failed pretext showing.
Accordingly, the evidence could not permit a reasonable jury to find that the EEO complaint was the but-for cause of
the termination.
C. Impact
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Protected activity survives withdrawal: The opinion strengthens plaintiffs’ ability to rely on
filed-but-withdrawn internal complaints as the protected activity for Title VII retaliation, foreclosing an
employer-friendly “withdrawal defeats protection” argument and aligning doctrine with Title VII’s deterrence-based
purpose.
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Temporal proximity remains contextual, but not self-sufficient: The decision illustrates that even
a short interval will not carry causation absent corroboration—especially where the employer has a documented,
safety-related rationale and the employee admits key misconduct.
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Comparator evidence must be built on proof, not assertion: The court’s treatment of three
unsupported comparators is a practical reminder that plaintiffs must place admissible record evidence of the
comparator’s conduct and the employer’s response into the summary-judgment record.
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Decisionmaker and probationary status are powerful differentiators: By treating the identity of
the decisionmaker and probationary status as dispositive “other variables,” the court signals that comparators from
different managerial regimes or employment statuses will often fail at the threshold.
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Waiver doctrine polices “cat’s paw” and similar theories: The footnote underscores that plaintiffs
must distinctly develop theories (with supporting authority) and preserve them in the district court, or risk
forfeiture on appeal (Rock Hemp Corp. v. Dunn; Anderson v. Donahoe).
IV. Complex Concepts Simplified
- McDonnell Douglas framework
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A common method of proving discrimination with circumstantial evidence: the plaintiff first makes a basic showing
(including that similarly situated employees were treated better), the employer then gives a lawful reason, and the
plaintiff must show that reason is pretext.
- Pretext
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Not merely a wrong or unfair reason, but a dishonest one—an explanation that is a “lie” rather than a mistake or
business judgment (Sweatt v. Union Pac. R.R. Co.).
- Honest belief rule
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Courts do not decide whether the employer was correct; they ask whether the employer honestly believed its stated
reason when it acted (Harper v. C.R. England, Inc.).
- Similarly situated comparator
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A coworker used to test discrimination: to be comparable, the employee typically must share key features such as
similar standards, similar conduct, and the same decisionmaker, without meaningful differentiating circumstances
(Coleman v. Donahoe).
- Weingarten investigation
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An investigatory interview where a unionized employee can have union representation if the interview might lead to
discipline, derived from N.L.R.B. v. J. Weingarten, Inc..
- But-for causation (retaliation)
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The plaintiff must show the adverse action would not have happened without the protected activity, even if other
factors were also in play (Xiong v. Bd. of Regents of the Univ. of Wis. Sys.).
V. Conclusion
The Seventh Circuit’s decision in Hakeem Abayomi v. Douglas A. Collins reinforces two practical rules
in Title VII litigation. First, an employee’s filing of an EEO complaint remains protected activity even if
the complaint is later withdrawn—otherwise Title VII’s anti-retaliation goal would be undermined. Second, plaintiffs
must still prove causation and pretext with evidence: temporal proximity without corroboration, and comparator
theories without record support or without shared decisionmakers/status, will not defeat summary judgment—especially
where the employer’s explanation is supported by the plaintiff’s admissions and framed as an honest patient-safety
response.