Anthony Walker v. Ingersoll Cutting Tool Company
915 F.3d 1154
| 7th Cir. | 2019Background
- Anthony Walker, a machinist at Ingersoll since 2008, was involved in a workplace altercation with coworker Todd Rafferty on Oct. 21, 2014; the parties dispute whether physical contact or threats occurred.
- Supervisors separated them; Walker returned to work, Rafferty went home; both worked without incident the next day.
- On Oct. 23 Walker complained to supervisor Daniel Thompson, asked that Rafferty be disciplined, and expressed distrust/disrespect for supervisors and coworkers; Walker was suspended with pay that day and did not return to work.
- Thompson and his supervisor decided on Oct. 27 to terminate Walker (human resources was notified and began termination steps); Walker filed a police report and his attorney threatened suit on Oct. 29; formal termination occurred Nov. 18, 2014.
- Walker sued alleging Title VII racial discrimination (later abandoned) and Illinois retaliatory discharge for reporting a crime and for reporting the incident to the employer; district court granted summary judgment for Ingersoll, and Walker appealed only the state-law retaliatory-discharge claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court should have dismissed state-law claims after disposing of federal claims | Walker argued court should have relinquished supplemental jurisdiction once federal claims were dismissed | Ingersoll argued district court properly exercised discretion to decide state claims on the merits | Court held district court acted within its discretion to resolve the state-law claim on the merits |
| Whether Walker alleged retaliatory discharge for reporting a crime (causation) | Walker argued he was fired for reporting Rafferty’s assault to police (or for reporting to employer) | Ingersoll showed decision to fire was made Oct. 27, before Walker’s police report (Oct. 29); employer cited history of conflict and Walker’s stated distrust and disrespect | Held Walker failed to show causal connection; cannot show discharge was in retaliation for police report |
| Whether reporting the incident to employer is protected conduct invoking public policy | Walker contended his internal complaints about the assault were protected activity | Ingersoll argued at-will employment allows discharge absent a clear public policy; no authority shows internal complaint about a coworker bump is a protected public-policy activity | Court skeptical and held Walker did not identify a clear public-policy protection or evidence that reporting prompted the firing |
| Whether there was a genuine factual dispute on causation precluding summary judgment | Walker relied on sequence of events and asserted dispute about physical assault severity | Ingersoll produced contemporaneous evidence of the decision date and reasons for firing (conflict history, disrespect) | Court held Walker did not present affirmative evidence that retaliation was the primary reason; summary judgment affirmed |
Key Cases Cited
- Puffer v. Allstate Ins. Co., 675 F.3d 709 (7th Cir. 2012) (plaintiff waived challenge by failing to raise on appeal)
- Burritt v. Ditlefsen, 807 F.3d 239 (7th Cir. 2015) (summary-judgment review standard; draw inferences for nonmoving party)
- Hansen v. Bd. of Tr. of Hamilton Se. Sch. Corp., 551 F.3d 599 (7th Cir. 2008) (discretion to retain supplemental jurisdiction if federal claims dismissed on merits)
- Turner v. Mem’l Med. Ctr., 911 N.E.2d 369 (Ill. 2009) (elements of retaliatory discharge under Illinois law)
- Roger v. Yellow Freight Sys., Inc., 21 F.3d 146 (7th Cir. 1994) (plaintiff must show more than a sequential connection to prove causation)
- Palmateer v. Int’l Harvester Co., 421 N.E.2d 876 (Ill. 1981) (at-will employment and limits on public-policy exceptions)
- Abrisz v. Pulley Freight Lines, Inc., 270 N.W.2d 454 (Iowa 1978) (discharge for impugning company integrity does not violate public policy)