Paki Brown v. AMERICAN FOODS GROUP, LLC and GREEN BAY DRESSED BEEF, LLC

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted January 13, 2026*
Decided January 13, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
MICHAEL Y. SCUDDER, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 25-1853
PAKI BROWN,
Plaintiff-Appellant,
v.
AMERICAN FOODS GROUP, LLC
and GREEN BAY DRESSED BEEF, LLC,
Defendants-Appellees.
Appeal from the United States District
Court for the Eastern District of Wisconsin.
No. 1:23-cv-01623-WCG
William C. Griesbach,
Judge.
O R D E R
Paki Brown sued his former employers, American Foods Group, LLC, and Green
Bay Dressed Beef, LLC, alleging that they fired him in retaliation for his complaint
about a language barrier with his trainer in violation of Title VII. See 42 U.S.C.
§ 2000e-3(a). The district court entered summary judgment for the defendants,
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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concluding that Brown failed to present evidence that he engaged in a protected
activity. We affirm.
Because the case was resolved on cross-motions for summary judgment, we
recount the facts in the light most favorable to the losing party—here, Brown.
See Holcomb v. Freedman Anselmo Lindberg, LLC, 900 F.3d 990, 992 (7th Cir. 2018). Brown
began working for the defendants in March 2023. After his first week of training, Brown
told his trainer that he was having difficulty understanding him: The trainer spoke
English but is a native Spanish speaker. After Brown and the trainer were unable to
resolve the issue, Brown raised his concern with the trainer’s supervisor, who then
escalated it to a manager.
Brown then met with the supervisor and manager. During the meeting, the
manager asked whether the trainer had been speaking Spanish when communicating
with Brown. Brown responded that the trainer had been speaking English. The manager
then asked, “You understand English, right?” Offended by this comment, Brown stated
that he needed to “get out of [t]here,” walked past the manager and supervisor, and left
the meeting without explanation. (The manager and supervisor attested that Brown
became confrontational and hostile during the meeting, cursing at them and pointing
his finger in their faces. But to the extent that their accounts conflict with Brown’s sworn
deposition testimony, we do not credit them here.) Brown was fired within a day of the
meeting.
Brown sued his former employers, alleging that they fired him in retaliation for
complaining about an unlawful employment practice. See 42 U.S.C. § 2000e-3(a).
Specifically, Brown asserted that his employer discriminated against him based on his
national origin by assigning to him a trainer whose English he could not understand.
The parties both moved for summary judgment, and Brown failed to respond to the
defendants’ proposed findings of fact, which the court deemed admitted. The court
granted the defendants’ motion and concluded that Brown had not presented evidence
from which a reasonable jury could conclude that he complained about any unlawful
employment practice. The court accepted that disparate treatment based on language
may sometimes constitute national-origin discrimination. The court assumed that
Brown believed he was opposing an unlawful employment practice when he
complained about his trainer, but it concluded that his belief was not objectively
reasonable. It explained that the assignment of a trainer whose English Brown had
difficulty understanding alone did not constitute national-origin discrimination. The

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No. 25-1853 Page 3
court noted that Brown had presented no evidence that the defendants restricted him
from speaking English or treated him differently because he spoke English.
Brown appeals the district court’s grant of summary judgment, which we review
de novo. See Logan v. City of Chicago, 4 F.4th 529, 536 (7th Cir. 2021). Title VII prohibits
an employer from retaliating against an employee “because he has opposed any
practice made an unlawful employment practice” by the statute. 42 U.S.C. § 2000e-3(a).
To defeat summary judgment, Brown needed some evidence from which a jury could
conclude that (1) he engaged in statutorily protected activity, (2) he suffered an adverse
employment action, and (3) a causal connection existed between the two. Logan,
529 F.4th at 538. To establish that he engaged in a protected activity, Brown “must not
only have a subjective (sincere, good faith) belief that he opposed an unlawful practice;
his belief must also be objectively reasonable, which means that the complaint must
involve discrimination that is prohibited by Title VII.” Id. (quoting Scheidler v. Indiana,
914 F.3d 535, 542 (7th Cir. 2019)).
The objective reasonableness of Brown’s belief is assessed by examining whether
the conduct “falls into the category of conduct prohibited by the statute.” Id. (quoting
Lord v. High Voltage Software, Inc., 839 F.3d 556, 563 (7th Cir. 2016)). In other words,
Brown must show that the complained-of conduct entailed a motive that Title VII
forbids—as relevant here, discrimination based on national origin. See id. at 538;
42 U.S.C. § 2000e-2(a).
Brown has developed no argument on appeal engaging with the district court’s
reasoning that the assignment of the trainer did not amount to an unlawful
employment practice prohibited by Title VII. So any argument along those lines is
waived. See Greenbank v. Great Am. Assurance Co., 47 F.4th 618, 629 (7th Cir. 2022). In any
event, we agree with the district court that Brown’s complaint did not involve national-
origin discrimination. Brown complained that he had been assigned a trainer whose
English he had difficulty understanding. Whether this assignment may have resulted in
Brown receiving ineffective training, it does not reflect conduct proscribed by Title VII.
See Murphy v. Caterpillar Inc., 140 F.4th 900, 914–15 (7th Cir. 2025) (explaining that courts
do not “second-guess[] employers’ business judgments” in the absence of
discriminatory intent). Brown spoke English at work, and he presented no evidence that
the defendants placed any restrictions on his use of English or otherwise treated him
differently than other employees because he spoke English.
Moreover, even if Brown could establish that he complained about
discrimination prohibited by Title VII, he has not presented sufficient evidence from

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which a reasonable jury could infer that he was fired because of his complaint. Brown
relies solely on temporal proximity, pointing out that he was fired within a day of his
complaint. While timing can support an inference of causation, see Loudermilk v. Best
Pallet Co., LLC, 636 F.3d 312, 315 (7th Cir. 2011), it is rarely sufficient alone, especially
where there is an intervening event and no evidence of pretext. See Smeigh v. Johns
Manville, Inc., 643 F.3d 554, 561 (7th Cir. 2011). Here, the manager said he fired Brown
because Brown became hostile during the meeting to discuss his complaint. Brown
contests the manager’s account of the meeting, but he does not dispute that he walked
out of the meeting without explanation. Brown has presented no evidence that the
proffered reason for his firing was pretextual. See Crain v. McDonough, 63 F.4th 585, 593
(7th Cir. 2023) (“Pretext is not ‘just faulty reasoning or mistaken judgment on the part of
the employer; it is [a] lie, specifically a phony reason for some action.’” (quoting Burton
v. Bd. of Regents of Univ. of Wis. Sys., 851 F.3d 690, 698 (7th Cir. 2017))).
Finally, Brown mentions ten errors he believes the district court committed
variously related to discovery and docket management. For example, he says that the
court abused its discretion by denying Brown’s request to compel discovery related to
his allegations of systemic discrimination. But all of these arguments are “perfunctory
and undeveloped,” so they are waived. Crespo v. Colvin, 824 F.3d 667, 674 (7th Cir. 2016).
AFFIRMED

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