Marvin Bowman v. City of Chicago Board of Education

the Board because Bowman's evidence did not create a triable issue of material fact. We affirm.

Since becoming a teacher in 2004, Bowman, a self-identified "Bible-Christian,"

routinely requested a few days off each year for religious observances. These requests were routinely approved by school officials. This changed in 2017 when Ali Muhammed became the interim principal at Bowman's school. During his first year, Muhammed hosted a staff event where he shared his recent conversion from Islam to a form of Christianity and invited the school community to attend a religious service held in the school building after hours. Bowman declined to participate, citing his opposition to using the school for religious purposes and his confidence in his own faith. Shortly after this event, school officials began questioning why Bowman wanted certain days off and allegedly withheld Bowman's pay for two previously approved religious-leave days. After Muhammed became principal on a permanent basis, Bowman's classes also began to include a higher number of students with disabilities than allowed by the collective-bargaining agreement between the school and teachers' union. When Bowman reported the imbalance to Muhammed, the principal told him,

"You don't praise the Lord and you got to praise the Lord." Because Muhammed failed to address the imbalance and Bowman found his comment insulting, Bowman filed union grievances and a complaint with the Illinois State Board of Education. Bowman attested that he encountered additional problems at school shortly thereafter. The temperature in his classroom fluctuated. Muhammed began avoiding him. And another teacher videotaped Bowman during a meeting without Bowman's knowledge and edited it in an embarrassing way.

Bowman sued the Chicago Board of Education, alleging, as relevant here, religious discrimination, retaliation, and harassment under 42 U.S.C. § 2000e-2(a)(1). Bowman's claims centered on the school officials' response to his requests for religious leave, the composition of his classes, and the other challenges he faced at the school, all of which he attributed to his religion and to his complaints about Muhammad's treatment of him.

The Board sought summary judgment on all claims, and the court granted the motion in its entirety. On the religious discrimination claim, the court concluded that Bowman failed to furnish evidence that supported a Title VII discrimination claim under both the burden-shifting framework of McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-03 (1973), and the holistic approach of Ortiz v. Werner Enterprises, Inc., 834 F.3d 760, 765-66 (7th Cir. 2016). Specifically, the court determined that Bowman had

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not suffered an adverse employment action, and even if he had, the Board provided legitimate, non-discriminatory reasons for its actions. Regarding the retaliation claim, the court determined that Bowman failed to produce evidence that any action was motivated by his protected activities. Finally, the court held that Bowman did not demonstrate that any harassment was motivated by his religion. Bowman appeals. We review the district court's grant of summary judgment de novo, viewing the facts in the light most favorable to Bowman. See Anderson v. Street,

104 F.4th 646, 651 (7th Cir. 2024). We first address his claim of discrimination, and then his claims of retaliation and harassment.

In religious discrimination cases under Title VII, the central inquiry is "whether the plaintiff has introduced evidence that would 'permit a reasonable factfinder to conclude that the plaintiff's … religion … caused the discharge or other adverse employment action.'" Mitchell v. Exxon Mobil Corp., 143 F.4th 800, 809 (7th Cir. 2025) (quoting Igasaki v. Ill. Dep't of Fin. & Pro. Regul., 988 F.3d 948, 957 (7th Cir. 2021)). An adverse employment action is any "harm" that leaves the plaintiff "worse off" with respect to an "identifiable term or condition of employment." Muldrow v. City of St. Louis, 601 U.S. 346, 354-55 (2024)^†; Thomas v. JBS Green Bay, Inc., 120 F.4th 1335, 1337 (7th Cir. 2024). It need not be "material," "significant," or "substantial." Thomas,

120 F.4th at 1337. Examples include delaying training, denying vacation times, transferring shifts, and considering family circumstances in a biased way. Id. Bowman did not show that he suffered an adverse employment action. His primary allegation—that his classes had a disproportionate number of students with disabilities—may have affected his daily responsibilities and left him feeling unsupported. But under Muldrow, this does not qualify as an adverse action because the issue was school-wide and not unique to him. Bowman's own evidence—a spreadsheet of class compositions for the 2021-22 school year—confirms that the composition of many general education classes exceeded the proportion of special education students permitted by the collective-bargaining agreement. While Bowman argues that the overages were limited to non-core classes exempt from the agreement, the data also shows that core subjects like English, science, and social studies were affected. His further argument that the data is inaccurate, alleging school officials manipulated student records to deflate his percentages, is unsupported. Although the imbalance may have impacted Bowman's working conditions, a broad issue affecting multiple teachers † The district court's summary-judgment ruling predates Muldrow.

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does not support his claim of individualized mistreatment. See Arnold v. United Airlines, Inc., 142 F.4th 460, 470-71 (7th Cir. 2025) (minor changes within the normal scope of employment did not constitute an adverse action under Muldrow). Bowman's other alleged adverse action—the denial of his requests for religious time off—is not supported by the record. The Board submitted documentation showing that each of Bowman's time-off requests was approved and that he was compensated accordingly. Although there were some delays in approvals and payments, the Board explained that district policy requires audits of such requests. The classroom- temperature issues, Muhammad's avoidance of him, and the teacher videotaping him also did not affect the terms or conditions of Bowman's employment—every aspect of his job remained the same. These slights do not constitute adverse employment actions under Muldrow.

Bowman likewise cannot establish a Title VII retaliation claim. To succeed on such a claim, Bowman must demonstrate that he engaged in a protected activity, suffered an adverse employment action, and that a causal connection exists between the two. See Anderson, 104 F.4th at 654. In the retaliation context, the standard for an adverse employment action is more demanding than in a discrimination claim: Instead of requiring only "some harm," the action must be materially adverse—meaning it results in "significant" harm. Est. of Harris v. City of Milwaukee, 141 F.4th 858, 869 (7th Cir. 2025) (citing Muldrow, 601 U.S. at 350, 357-58); see also Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 68 (2006). Because Bowman cannot establish an adverse employment action for his discrimination claim, he necessarily cannot meet the higher standard for his retaliation claim.

Bowman likewise cannot establish a Title VII harassment claim because he did not endure conduct that was severe or pervasive. To prevail on a hostile work environment claim, Bowman must show: "(1) [his] work environment was objectively and subjectively offensive, (2) the harassment [he] complained of was based on [his religion], (3) the conduct was so severe or pervasive as to alter the conditions of employment and create a hostile or abusive working environment, and (4) there is a basis for employer liability." See Anderson, 104 F.4th at 652 (citation modified); see also Vance v. Ball State Univ., 570 U.S. 421, 427 (2013). Bowman fails to satisfy this standard, as the incidents he alleges—delays in approving religious leave, disproportionate assignment of special-education students, Muhammad's avoidance, classroom temperature fluctuations, and video surveillance by another teacher—do not constitute the type of severe or pervasive conduct necessary

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to support a harassment claim under Title VII. See Rongere v. City of Rockford, 99 F.4th 1095, 1105 (7th Cir. 2024) (pay complaints, social marginalization, and longer hours are not severe or pervasive); Abrego v. Wilkie, 907 F.3d 1004, 1015 (7th Cir. 2018) (excessive monitoring is not sufficient).

Lastly, although Muhammed's comment concerning Bowman's religious beliefs is troubling, an isolated remark (unless extremely serious) does not constitute a change in the terms and conditions of employment. See Faragher v. City of Boca Raton, 524 U.S. 775, 788 (1998). Muhammed's comment was insufficiently serious to rise to that level. Cf., Shanoff v. Ill. Dep't of Human Servs., 258 F.3d 696, 699, 705-06 (7th Cir. 2001) (concluding that a hostile work environment was created when a supervisor made statements such as "I hate everything that you are" and "I know how to put you Jews in your place").

For these reasons, the judgment of the district court is AFFIRMED.

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