Police officer brought action alleging employment discrimination under Age Discrimination in Employment Act (ADEA) and Title VII, and retaliation in violation of the First Amendment. Employer moved for summary judgment. The United States District Court for the Northern District of Illinois granted motion. Employee appealed. The Court of Appeals held that: (1) officer failed to establish discriminatory intent under ADEA or Title VII; (2) officer failed to establish prima facie case of age discrimination; (3) employment assignments did not constitute material adverse actions sufficient to establish retaliation under Title VII; (4) officer failed to establish prima facie case of retaliation under Title VII; and (5) officer's speech at union meeting was not constitutionally protected for purposes of First Amendment retaliation claim.
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