## Facts

- Molly Joll, a teacher with over 25 years at a middle school, previously co-coached middle-school cross-country and resigned in 2013 citing competing family commitments.
- In 2014, Joll applied for two assistant coaching positions at the district’s high school: (1) girls’ cross-country and (2) boys’ cross-country.
- For the girls’ position, the finalists were Joll and a younger male candidate; Joll’s evidence was that interviewers concentrated on her prior resignation and childcare/family responsibilities rather than her coaching experience, while the male candidate was asked about experience and coaching approach.
- Joll’s references for the girls’ position were contacted unusually quickly compared to ordinary practice; the male candidate’s references were contacted on the usual timeline.
- The district selected the male candidate, citing his more recent experience with high-school athletes.
- For the boys’ position, the finalists were Joll and a younger male high-school teacher; Joll testified the interview again emphasized family obligations and her references were handled differently.
- The district selected the male candidate, citing his stronger rapport with athletes because he already taught at the high school, despite his lack of recent coaching experience.
- Joll sued alleging sex discrimination under Title VII and age discrimination under the ADEA based on both non-selections.
- The district court granted summary judgment to the school district on both claims.

## Issues

1. Whether the record, viewed as a whole, permitted a reasonable jury to find that sex discrimination motivated the district’s failure to hire Joll for either assistant coaching position under Title VII.
2. Whether the evidence permitted a reasonable jury to find that age was the but-for cause of the failure-to-hire decisions under the ADEA.

## Decision

- Reversed summary judgment on the Title VII sex-discrimination claim and remanded for trial.
- Affirmed summary judgment on the ADEA age-discrimination claim.
- Held the district court erred by evaluating evidence in isolated pieces rather than cumulatively when determining whether a triable inference of discrimination existed.

## Legal Principles

- Summary judgment in discrimination cases turns on whether all evidence, considered together, allows a reasonable inference that discrimination caused the challenged action; courts should not require any single item of evidence to “prove the case by itself.”
- Sex-role stereotyping (including interview questions reflecting gendered assumptions about childcare or motherhood) is probative evidence of sex discrimination under Title VII.
- Procedural irregularities, selective enforcement of hiring criteria, and shifting or inconsistently applied justifications can support a finding of pretext and permit an inference of discriminatory intent.
- Under the ADEA, the plaintiff must produce evidence from which a jury could find age was the but-for cause of the adverse decision; showing that selected candidates were younger is insufficient without evidence tying age to the decisionmakers’ motive.

## Conclusion

The Seventh Circuit held that Joll presented enough combined circumstantial evidence—stereotype-inflected interviewing, irregular hiring procedures, and inconsistent rationales favoring male candidates—to require a jury trial on her Title VII sex-discrimination claim, but she lacked evidence that age was the determinative cause of the decisions, so her ADEA claim failed as a matter of law.


Joll v. Valparaiso Cmty. Sch., 953 F.3d 923 (7th Cir. 2020)