Seventh Circuit: Susan Shott v. Robert Katz


FRCP, S1981, Discrimination


Where a claim is dismissed without prejudice, an appeal filed prior to the final date for amendment becomes timely after that date has passed.

Under S1981, the claimed retaliation need not be employment-related.  It suffices that the claim arise from contract or employment-related events.

Implied retaliation by co-workers theory implies some level of agency with the employer.

Susan Shott v. Robert Katz