In Golden v. Presence Cent. & Suburban Hosps. Network, No. 25 C 5765, 2026 WL 2389628 (N.D. Ill. Aug. 17, 2026), the court held that plaintiff failed to plausibly allege discrimination or hostile work environment based on race or religion under Title VII of the Civil Rights Act of 1964.
From the decision:
Golden is a Black woman who is a Christian. She alleges that Presence began discriminating against her on September 18, 2023. Golden does not provide any details about the discrimination other than that it was committed by her supervisor who is white. Golden also alleges that she reported this discrimination. Ultimately, Golden alleges that after reporting illegal conduct, she was subjected to escalating harassment and discrimination, including being terminated on May 14, 2024. Golden does not include any additional facts in her complaint about the alleged discrimination and harassment.
Golden’s primary claim is that she was fired because she is Black and Christian. With regard to race discrimination under Title VII, a plaintiff need only allege that his employer fired him because of his race. This is a low bar. As the Seventh Circuit has explained, all a complaint has to say is “I was turned down for a job because of my race.”
Nevertheless, there must be some facts that make the wrongful discharge contention plausible. A plaintiff asserting a discrimination claim cannot rely on generalized allegations alone, however, but must combine them with facts particular to his case to survive a motion to dismiss.
Here, Golden includes no factual allegations directly or indirectly connecting her termination with her race or religion. See, e.g., Tucker v. Ettleson Hyundai, LLC, No. 19 C 4334, 2019 WL 6327424 (N.D. Ill. Nov. 25, 2019) (finding that the plaintiff’s allegation that he was fired after raising a legitimate complaint against a white employee, permits the plausible inference that the employer would not have fired a white employee for making an analogous complaint). Due to this lack of even minimal factual allegations about how she was treated at Presence, Golden’s claim that she was fired because of her race and religion must be dismissed.
Golden also claims that she was discriminated against and harassed during her employment. But Golden has not made any allegations at all about how she was treated while she was still employed at Presence. Without some allegations about what happened during her employment, she cannot plausibly claim that the way she was treated constitutes discrimination and harassment.
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Accordingly, the court held that dismissal of these claims was warranted.