The U.S. Court of Appeals for the Seventh Circuit recently erased the victory of the Good Samaritan Ministries in an employee termination case, Ledbetter v. Good Samaritan Ministries, et al., — F.3d —- (7th Cir. Feb. 6, 2015), sending the case back to the trial court for further litigation.
The employee, Linzie Ledbetter (male), worked in a homeless shelter and food pantry. After a shelter resident complained about Ledbetter’s alleged threat to evict her, Ledbetter’s supervisors met with him and warned him that such behavior could result in disciplinary action, including termination. As a result, Ledbetter filed an EEOC charge—and later, a federal lawsuit—claiming race discrimination and retaliation under Title VII of the Civil Rights Act of 1964.
Shortly thereafter, Ledbetter filed a second EEOC charge for race discrimination and was subsequently warned again about his behavior toward the shelter residents and toward his co-workers. The day after his supervisors learned of the second EEOC charge, they fired Ledbetter, prompting a third EEOC charge and another lawsuit for retaliation.
In the trial court, Good Samaritan Ministries and its supervisors argued that Ledbetter’s termination was not prompted by the second EEOC charge, because they had decided to fire him five days before they even knew of the charge. The trial court agreed with their argument and granted summary judgment in their favor.
The appellate court, however, studied the details of the supervisors’ stories and found a number of inconsistencies. The court also noted that the supervisors’ actions created a possible inference that their actions were, indeed, motivated by Ledbetter’s EEOC charge. The court found “too many loose ends” to uphold the employer and supervisors’ victory, and remanded the case to the trial court for further proceedings.
This case is a good example of the need for solid documentation, detailed factual analysis, and consistency in word and action in employee dismissal cases. Though Ledbetter’s actions toward shelter residents, if true, may well have justified his termination, the employer’s actual implementation of the dismissal may well have been its undoing.
To discuss your employee discipline issues or claims of retaliation, contact Vanessa Clohessy or Jeff Goelitz.