Case Explained: BRENDA KOEHLER v. INFOSYS TECHNOLOGIES LIMITED, INC. and INFOSYS PUBLIC SERVICES, INC

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-13

The Seventh Circuit affirmed the district court’s grant of summary judgment to Infosys Technologies Limited, Inc. and its affiliates in a Title VII and § 1981 employment discrimination case brought by four non-South Asian plaintiffs alleging disparate treatment and disparate impact based on race and national origin. The court held that the district court did not abuse its discretion in excluding the plaintiffs’ expert testimony under Federal Rule of Evidence 702, finding that the expert, David Neumark, lacked the necessary qualifications to perform his “name-matching” methodology to identify South Asian individuals and failed to provide evidence establishing the reliability of his methods. Consequently, the court affirmed the denial of class certification, as the plaintiffs conceded they could not satisfy Federal Rule of Civil Procedure 23 requirements without the excluded statistical analysis. The court also affirmed the denial of leave to supplement summary judgment briefing with demographic data from PeopleFluent, ruling that the district court acted within its inherent discretion to manage proceedings and prevent delays, particularly given that the plaintiffs had previously been offered opportunities to utilize this data years earlier but failed to do so. Finally, the court upheld the dismissal of the plaintiffs’ individual claims, determining that under the *McDonnell Douglas* burden-shifting framework, the plaintiffs failed to demonstrate that Infosys’s nondiscriminatory reasons for their employment actions were pretextual and that the evidence presented did not meet the high threshold required for a constructive discharge claim.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.