Chris Schaffhauser v. United Parcel Service, Inc.
794 F.3d 899
| 8th Cir. | 2015Background
- Schaffhauser, a white male, was Plant Engineering Manager at UPS from 2007 until demoted to supervisor in 2012 after he made a racially charged remark to co-workers.
- The comment: “If he ever hit me, I would hit him back so hard it’d knock the black off him.” Schaffhauser admitted he made the comment, called it a mistake, and said he had not intended it as racist.
- UPS has a Professional Conduct and Anti-Harassment Policy prohibiting derogatory or inappropriate remarks; Schaffhauser had received training on these policies.
- After the incident, Barefield filed grievances; UPS’s human resources director demoted Schaffhauser and denied informal EDR meeting and peer review.
- Schaffhauser sued for reverse race discrimination (Title VII, § 1981, ACRA) and failure to accommodate a disability (ADA, ACRA), arguing his medical condition (steroid shot effects) contributed to the comment and that UPS failed to accommodate.
- The district court granted summary judgment for UPS; the Eighth Circuit affirmed, holding UPS articulated a legitimate nondiscriminatory reason (policy violation) and Schaffhauser failed to show pretext or that he timely requested an accommodation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reverse-race discrimination (Title VII, §1981, ACRA) | Schaffhauser argued demotion was discriminatory and UPS failed to follow EDR process and treated others differently, showing pretext | UPS argued it demoted him for violating anti-harassment policy via the racially offensive comment; investigatory variances not tied to race | Affirmed for UPS: no direct evidence; UPS offered legitimate nondiscriminatory reason; plaintiff failed to show pretext or similarly situated comparators |
| Failure to accommodate (ADA and ACRA) | Schaffhauser contended steroid shot caused neurological/behavioral effects and requested accommodation after the incident | UPS argued Schaffhauser never timely initiated the interactive process or requested formal accommodation before misconduct | Affirmed for UPS: request came only after misconduct and after adverse action was imminent, so he did not satisfy the employer-notice/interactive-process requirement |
Key Cases Cited
- Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. en banc 2011) (summary judgment and direct-evidence standard)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
- Davis v. KARK-TV, Inc., 421 F.3d 699 (8th Cir. 2005) (race-discrimination standards across statutes)
- Bone v. G4S Youth Servs., LLC, 686 F.3d 948 (8th Cir. 2012) (employer’s burden to articulate legitimate nondiscriminatory reason)
- Hammer v. Ashcroft, 383 F.3d 722 (8th Cir. 2004) (reverse-race background-circumstances requirement)
- Peyton v. Fred’s Stores of Ark., Inc., 561 F.3d 900 (8th Cir. 2009) (interactive process requirement for ADA accommodations)
- EEOC v. Convergys Customer Mgmt. Grp., 491 F.3d 790 (8th Cir. 2007) (employee must give employer notice and details to initiate interactive process)
- Hill v. Kansas City Area Transp. Auth., 181 F.3d 891 (8th Cir. 1999) (timeliness of accommodation requests made after misconduct)