Case Explained: AISHA PUTNAM v. CARAMELCRISP, LLC d/b/a GARRETT POPCORN SHOPS

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-13 The seventh-circuit dismissed Aisha Putnam’s challenges to various trial-related rulings for failure to provide complete trial transcripts necessary to assess prejudice, and affirmed the district court’s summary judgment ruling on her Food Safety Modernization Act (FSMA) retaliation claim as well as the dismissal of her common law retaliatory discharge claim. The court applied the four-element framework for whistleblower retaliation claims under the FSMA, requiring a plaintiff to prove: (1) engagement in protected activity; (2) employer knowledge of that activity; (3) an unfavorable personnel action; and (4) that the protected activity was a contributing factor in the adverse action. Regarding the FSMA claim based on emails sent to the FDA, the court affirmed summary judgment because Putnam failed to present evidence that any decisionmaker at CaramelCrisp had actual knowledge of her anonymous complaints, which is a threshold requirement for establishing causation. The court further held that the district court did not abuse its discretion in refusing to allow Putnam to assert a new retaliation theory based on the defendant’s trade secrets lawsuit after she had previously argued those cases were distinct and during the trial phase. Regarding the common law claim, the court affirmed the dismissal without deciding whether Illinois law permits such a claim when an adequate statutory remedy exists. The court reasoned that because the jury found under the FSMA’s “contributing factor” standard—which is a lower causation threshold than the “because of” standard required for common law claims—that Putnam’s complaints were not a contributing factor in her termination, she cannot relitigate the issue to meet the higher common law standard. The practical consequence is that the judgment in favor of CaramelCrisp stands; Putnam’s appeal regarding trial errors is dismissed due to an incomplete record, and her substantive claims are affirmed based on the jury’s verdict and the lack of evidence regarding employer knowledge. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.