## Facts

- Becky Chambers worked for American Trans Air, Inc. (ATA) from October 1982 to July 1987, including roles as a contract administrator and crew planner.
- In June 1987, Chambers delivered a letter stating she would resign effective July 18 unless ATA met demands including increased pay and additional staffing; ATA accepted the resignation.
- Chambers filed an EEOC charge and later sued ATA under Title VII, alleging sex discrimination theories including failure to promote, unequal pay, denial of training, hostile work environment, and constructive discharge.
- The district court granted summary judgment to ATA on all Title VII claims and imposed Fed. R. Civ. P. 11 sanctions on Chambers’s attorney for advancing certain theories deemed legally unsupported.
- Chambers appealed both the adverse merits judgment and the sanctions order.

## Issues

1. Whether Chambers produced sufficient evidence to create a genuine dispute of material fact on any Title VII theory asserted (including pay, promotion, hostile environment, constructive discharge, and related claims).
2. Whether some asserted theories were barred because they were untimely or outside the scope of the EEOC charge.
3. Whether Rule 11 sanctions against Chambers’s counsel were warranted for pursuing claims lacking factual or legal support.

## Decision

- The Seventh Circuit affirmed summary judgment for ATA on all Title VII claims.
- The court held that Chambers failed to meet her summary-judgment burden to identify specific evidence creating a triable issue.
- The court agreed that certain allegations were time-barred and that some theories (including failure-to-promote) were not within the scope of the EEOC charge.
- The court affirmed the Rule 11 sanctions, concluding counsel advanced legally untenable Title VII theories without adequate grounding.

## Legal Principles

- On summary judgment, once the movant shows entitlement to judgment, the nonmovant must present specific admissible facts showing a genuine issue for trial; conclusory assertions and unsupported allegations are insufficient.
- Title VII claims generally must be timely presented through the administrative charge-filing process, and subsequent litigation is limited to matters reasonably encompassed by the EEOC charge.
- Pay discrimination claims require evidence permitting an inference that compensation decisions were based on sex, such as comparator evidence or other proof linking pay to discriminatory intent.
- Constructive discharge requires working conditions so intolerable that a reasonable person would feel compelled to resign; an employer’s acceptance of a conditional resignation demand does not alone establish intolerability.
- Rule 11 permits sanctions when an attorney files or maintains claims not warranted by existing law (or a nonfrivolous argument for change) or lacking evidentiary support after reasonable inquiry.

## Conclusion

The Seventh Circuit upheld judgment for ATA because Chambers did not present evidence sufficient to reach trial and because key theories were unexhausted or untimely under Title VII’s administrative scheme; it also affirmed Rule 11 sanctions where counsel pursued Title VII theories lacking a sound legal basis.


Chambers v. Am. Trans Air, Inc., 17 F.3d 998 (7th Cir. 1994)