Jacqueline A. Watkins v. City of Chicago, Illinois

Whether, considering the “cat’s paw” employment theory in what circumstances, an employer can be liable for racial and sex discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., based on the alleged bias of a supervisor, where the supervisor did not take the adverse employment action himself but is alleged to have caused that action.

Whether the Title VU’s retaliation provision and similarly worded statues intertwined with the ‘blue code of silence” require a plaintiff to prove butfor-causation (i.e., that an employer would not have taken an adverse employment action but for improper motive), or instead require only proof that the employer had a mixed motive (i.e., that an improper motive was one of multiple reasons for the employment action).

Whether an employer refusal to open plaintiff complaints of discrimination, pretext, and file an EEOC discrimination complaint against biased supervisor was abuse of discretion, Federal Rules of Civil Procedures, Bill of Rights, and violated plaintiff remedial purposes of Title VII protections that severely limited plaintiff procedural due process, constitutional rights, and denial of trial to be heard among a jury of plaintiff peers.

Whether stray remarks can be used to prove causation to an adverse employment action under Title VII claims.