Case Explained: RUSSIA BROWN v. CHICAGO TRANSIT AUTHORITY and AMALGAMATED TRANSIT UNION, LOCAL 241

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-06-24 The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the Chicago Transit Authority (CTA) and the Amalgamated Transit Union, Local 241, rejecting Russia Brown’s claims of transgender discrimination, retaliation, and FMLA violations. The court held that Brown failed to present sufficient evidence to create a genuine issue of material fact on any of his claims under Title VII or the Family and Medical Leave Act (FMLA). The court applied the *McDonnell Douglas* burden-shifting framework for Title VII discrimination claims, requiring Brown to establish a prima facie case including a valid comparator. The court found Brown failed to identify a similarly situated employee outside his protected class who was treated more favorably, as his citation regarding another operator lacked critical details about that individual’s status and conduct. Regarding pretext, the court determined Brown offered only unsupported assertions that the CTA’s reason for termination—falsification of FMLA leave records—was a lie, failing to meet the high bar required to prove discriminatory animus. For retaliation claims against both the CTA and the union, the court applied the “but-for” causation standard, concluding that the multi-year gap between Brown’s protected activity (advocacy regarding bathroom access and insurance) and his termination was too remote to support an inference of causation without additional evidence, which Brown failed to substantiate with proper record citations. Additionally, regarding FMLA interference, the court upheld the denial of leave because Brown did not cooperate in obtaining a required third medical opinion, binding him to the second opinion that found him ineligible for leave. The court also affirmed procedural rulings that Brown’s failure to properly cite evidentiary support under Local Rule 56.1 and Federal Rule of Civil Procedure 56(c) meant his factual assertions were disregarded, as courts are not obligated to scour the record for evidence on behalf of a non-moving party. The practical consequence is that the district court’s judgment in favor of the defendants stands, meaning Brown’s lawsuit is dismissed with no relief granted and no trial ordered. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.