Marvin Bowman, a self-identified Bible-Christian, had taught in the Chicago Public School District for years and regularly took religious leave for observance. He filed suit against the Chicago Board of Education, alleging discrimination based on his religious beliefs and retaliation for reporting mistreatment. In particular, Bowman claimed that his working conditions changed after Ali Muhammed was appointed interim principal at his school in 2017. Bowman alleged that during his first year, Principal Muhammed hosted a staff event where he shared his recent conversion from Islam to a form of Christianity and invited staff to attend a religious service held after hours on campus. Bowman, citing his own religious convictions, declined to attend. Bowman alleged that Principal Muhammed treated him less favorably after he declined the invitation.
Bowman asserted that Principal Muhammed’s conduct included assigning more students with disabilities to his classroom, delaying or mishandling his religious leave requests, and withholding his pay for absences that had been previously approved. He also alleged that after filing complaints internally and to the Illinois State Board of Education, he experienced further mistreatment, including being ignored by school leadership, subjected to cold working conditions, and secretly recorded in a video edited to embarrass him. Bowman characterized these actions as religious discrimination, retaliation, and a hostile work environment in violation of Title VII.
The trial court granted summary judgment to the Board on all claims, and the Seventh Circuit affirmed. In religious discrimination cases under Title VII, the evidence must show that plaintiff’s religion caused an adverse employment action. An adverse action is any harm that leaves the plaintiff worse off with respect to a term or condition of their employment, for example, delaying training, denying vacation, and transferring shifts.
The Court of Appeals found that Bowman failed to establish an adverse employment action sufficient to support his discrimination or retaliation claims. Although Bowman believed he was assigned an excessive number of students with disabilities, the record showed that this was a system-wide issue affecting many teachers. His religious leave requests were ultimately granted, and the temporary pay withholding was a result of a routine audit process, not discriminatory intent. Other alleged harms, such as fluctuating room temperatures and social avoidance by school leaders, did not constitute materially adverse employment actions under Title VII’s legal standard.
The Court then considered the retaliation claim. To succeed on a retaliation claim, a plaintiff must demonstrate he engaged in a protected activity, suffered an adverse employment action, and that a causal connection exists between the two. The Court noted that, like the religious discrimination claim, none of the incidents Bowman described rose to the level of an adverse employment action.
The Court also rejected his hostile work environment theory, explaining that the conduct alleged was not severe or pervasive. While the principal’s remark that “you don’t praise the Lord and you got to praise the Lord” may have been inappropriate, it was an isolated incident and not enough to alter the conditions of Bowman’s employment.
The Court concluded that Bowman’s claims failed as a matter of law and affirmed the trial court’s ruling in full.
Bowman v. City of Chicago Board of Education, (7th Cir. 2025), 2025 U.S. App. LEXIS 25503.
Note: This case reinforces that to sustain a Title VII discrimination or retaliation claim, an employee must show more than workplace tension or discomfort. Allegations of unfair treatment must be tied to an adverse employment action, which can include things like changes to pay, assignments, or job duties.