A Seventh Circuit panel affirmed summary judgment on a Carmel Crisp research director’s retaliation claims under the Food Safety Modernization Act and Illinois common law after her firing.
The court said she failed to show the employer decision-makers knew about her anonymous FDA emails, undercutting her federal whistleblower theory.
A jury’s finding of no causal link between her food-safety complaints to management and her termination also defeated the Illinois claim, which required an even higher causation showing.
The ruling leaves intact the lower-court dismissal of both claims and narrows the path for retaliation suits built on anonymous external complaints.