Madlock v. WEC Energy Group, Inc.

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Madlock, an African American woman, has worked at WEPCO since 1977. While Madlock was working in the Industrial Billing section, she was not in management, but was a point person for her team of “billers.” In 2011, WEPCO assigned a new management team, to perform a comprehensive review and institute metrics to measure performance. Wrycza, a white woman, became Madlock’s supervisor. The two did not get along. Madlock’s conduct, such as personal phone use, had already drawn the attention of management, and under Wrycza, Madlock’s conduct came under greater scrutiny. Wrycza followed WEPCO’s graduated discipline system to deal with billing errors and Madlock’s use of unprofessional language. Madlock was transferred to a different department, where she worked between two managers. The transfer did not affect Madlock’s title or salary, but co‐workers described it as a demotion and "a total humiliation." Madlock’s new supervisor, Phillips, a black woman, prompted Madlock to file an internal discrimination complaint against Wrycza. Madlock made another billing error. Madlock’s grievances were denied; the Vice President of Customer Service expressed shock at Madlock's errors. Madlock was denied a promotion due to her work record. Madlock sued (42 U.S.C. 1981), alleging racial discrimination and retaliation. The Seventh Circuit affirmed summary judgment for WEPCO, noting that the transfer caused no material change in Madlock’s employment and was not an adverse employment action. Madlock cannot show a sufficient causal link between her internal complaint and the alleged adverse actions. View "Madlock v. WEC Energy Group, Inc." on Justia Law