Recently, the Seventh Circuit affirmed the district court's verdict in favor of a plaintiff-employee in an action alleging that his employer demoted him in retaliation for having participated in an investigation of his co-worker's discrimination claim, as well as for filing his own discrimination claim.
The record showed that Hick's supervisor (Thompson) told others that Hicks and his co-worker needed to be "gotten rid of" because they had lodged discrimination claims against said Thompson. The record also showed that Hick's demotion resulted in $9 per hour reduction in pay, which was sufficiently material so as to constitute actionable adverse act. The fact that the supervisor's remark was made 22 months prior to plaintiff's termination did not require a different result where the substance of the statement constituted direct evidence of retaliation. Moreover, the fact that the supervisor and the plaintiff did not enjoy an ideal working relationship did not preclude the Dist. Ct. from ordering that plaintiff be reinstated to his old position under the supervisor.
http://www.ca7.uscourts.gov/tmp/HE0N2GZN.pdf