Spengler v. Worthington Cylinders
615 F.3d 481, 2010 U.S. App. LEXIS 15304, 93 Empl. Prac. Dec. (CCH) 43,947 (2010)
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Rule of Law:
An employee may prove a claim of unlawful retaliation by presenting sufficient circumstantial evidence for a jury to reasonably disbelieve an employer's proffered legitimate, non-retaliatory reason for termination and infer that the actual motive was intentional retaliation. A plaintiff's prima facie case, combined with evidence showing the employer's justification is false, may permit a trier of fact to conclude the employer acted unlawfully.
Facts:
- In January 2004, Worthington Cylinders hired Jon Spengler, then fifty-three years old, as a seasonal employee.
- Spengler performed well, receiving positive evaluations and a recommendation for regular full-time (RFT) status from his supervisor, Dennis Huggins, in November 2004, though he was not selected.
- In December 2004, Huggins suggested Spengler transfer to another division, remarking that Spengler would "probably have trouble keeping up with the younger guys" in the cylinder division.
- Concerned by the comment, Spengler met with plant manager John Hoffman on January 16, 2005, to report his belief that he was facing age discrimination.
- Hoffman then discussed Spengler's complaint with Huggins.
- Following this discussion, Huggins' attitude toward Spengler became cold; he kept his distance and would not make eye contact.
- On February 9, 2005, Huggins terminated Spengler's employment, telling him it was due to negative comments from co-workers and that he would not be recommended for the other division or rehired in the future.
Procedural Posture:
- Jon Spengler filed a complaint with the Equal Employment Opportunity Commission (EEOC).
- After receiving a right-to-sue letter, Spengler sued Worthington Cylinders in federal district court for age discrimination and retaliation.
- The district court dismissed Spengler's state law claim.
- Worthington Cylinders moved for summary judgment; the district court granted it on the age discrimination claim, which Spengler conceded, but denied it on the retaliation claim.
- The retaliation claim proceeded to trial, and a jury returned a verdict in favor of Spengler, awarding lost wages and liquidated damages.
- The district court denied Worthington Cylinders' post-trial motion for judgment as a matter of law (Rule 50(b)).
- Worthington Cylinders (Appellant) appealed the denial of its motion to the U.S. Court of Appeals for the Sixth Circuit; Spengler is the Appellee.
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Issue:
Does sufficient evidence support a jury's finding that an employer terminated an employee in retaliation for complaining about age discrimination, in violation of the Age Discrimination in Employment Act, when the employer offers a legitimate, non-retaliatory reason for the termination?
Opinions:
Majority - Clay, J.
Yes, sufficient evidence supports the jury's finding that the employer terminated the employee in retaliation for his complaint. A plaintiff can prevail on a retaliation claim by establishing a prima facie case and providing enough evidence for a jury to reject the employer's proffered legitimate, non-discriminatory reason as pretext. Here, Spengler established a prima facie case by showing: 1) he engaged in a protected activity (complaining about age discrimination); 2) his employer knew; 3) he suffered an adverse action (termination); and 4) there was a causal connection. The causal link was supported by the close temporal proximity between his complaint and termination (less than a month), combined with other evidence like his supervisor's changed demeanor. Worthington's proffered reason—a '12-month rule' for seasonal employees—was successfully shown to be pretextual through testimony that the rule was only applied during production slowdowns, which had not occurred, and that other seasonal employees had worked longer than twelve months. Therefore, a reasonable jury could infer from the falsity of the employer's explanation that the true reason for termination was intentional retaliation.
Analysis:
This decision reaffirms the principle from Reeves v. Sanderson Plumbing Prods. that a jury can infer unlawful intent from the falsity of an employer's explanation for an adverse employment action. It clarifies that while temporal proximity alone is insufficient to prove causation in a retaliation claim, it becomes powerful evidence when combined with other circumstantial factors, such as a supervisor's changed attitude or proof that a company policy was selectively enforced. This case serves as a strong reminder for employers that seemingly neutral policies can be challenged as pretextual if not applied consistently, potentially exposing them to liability for retaliation.
