Kellie Wilson v. AIM Specialty Health

── Kellie Wilson v. AIM Specialty Health ── Court: Court of Appeals for the Seventh Circuit Date: May 27, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 23-3418 KELLIE WILSON, Plaintiff-Appellant, v. AIM SPECIALTY HEALTH, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:21-cv-01929 — Sara L. Ellis, Judge. ____________________ ARGUED FEBRUARY 4, 2025 — DECIDED MAY 27, 2026 ____________________ Before HAMILTON, JACKSON-AKIWUMI, and PRYOR, Circuit Judges. JACKSON-AKIWUMI, Circuit Judge. In 2012, Kellie Wilson, a Black woman, started working full-time for AIM Specialty Health. Throughout her tenure, she received merit-based sal- ary increases, but it took eight years for her to be promoted. Some of her non-Black colleagues received higher salaries from the start and were promoted more quickly. Witnessing this, Wilson sued AIM for disparate pay and failure to 2 No. 23-3418 promote under three statutes: Title VII, 42 U.S.C. § 1981, and the Illinois Human Rights Act (IHRA). AIM moved for sum- mary judgment on all Wilson’s claims, which the district court granted. Reasonable jurors could find that Wilson’s former super- visor disliked and, on at least one occasion, mistreated her. Reasonable jurors could also question, as faulty or mistaken, the reasoning behind AIM’s pay and promotion decisions. But neither finding would be enough under our employment discrimination caselaw to merit a trial. For Wilson’s case to proceed to trial, there must be evidence from which a jury could infer that AIM’s justifications for its pay and promotion decisions were falsehoods designed to hide racial discrimina- tion—in other words, pretext. This is where Wilson’s evi- dence falls short, so we are compelled to affirm. I We review the district court’s grant of summary judgment de novo, granting Wilson a favorable assessment of the record and all reasonable inferences. Johnson v. Accenture LLP, 142 F.4th 536, 542 (7th Cir. 2025). AIM is a medical benefits management company. The company’s IT department houses several business analyst po- sitions under the Business Support umbrella. These positions, in order of increasing salary range, are BA, BAII, BAIII, and Business Consultant. The chart below outlines the experience required for each position. No. 23-3418 3 Position Experience BA Entry-level role, no prior business analyst experience BAII Mid-level role, 3 to 5 years of baseline- type experience and some technical un- derstanding BAIII 5 to 7 years of experience and deep tech- nical understanding Business BA who also functions as team lead Consultant AIM’s parent company, Anthem, Inc., sets a salary range for each position. For each role, AIM uses market research and third-party consultants to set the starting compensation within the salary range based on data available for similar po- sitions. All BAs and Business Consultants at AIM receive a salary that falls within the assigned range. Managers there- fore cannot propose a salary outside of Anthem’s range. They may, however, propose starting a candidate at a higher salary within the range depending on the position being offered, the candidate’s experience, and the salary the candidate requests. AIM does not generally post promotion opportunities or internal openings on its website. When it does, employees do not receive automatic notification of the new postings. More commonly, it is up