Cotton v. Beaumont Health, 2:16-cv-12232

Background

Morris Cotton, age 57, was Director of Security at Oakwood Dearborn (part of Beaumont). He applied for several higher operations positions in 2013–2015 and alleges race and age discrimination and retaliation after filing an EEOC charge.
2013: Cotton applied for Administrator, Support Operations; final candidates selected but position was cancelled after initial offer to another candidate was rescinded.
2014: Cotton was offered a Director, Support Operations role but declined because Beaumont would not meet his compensation/hiring requests; that posting was then cancelled.
2015: Crothall (a contractor) expanded its role and promoted Chris Soop to General Manager with duties Cotton contends matched the 2013 Administrator role; Cotton learned of Soop’s role by Jan/Feb 2015. Also in Feb 2015 Cotton was passed over for System Director, Security (awarded to Christopher Hengstebeck); Cotton was made Deputy System Director and received a pay increase.
Cotton filed a single EEOC charge on December 23, 2015 alleging race and age discrimination for Soop’s and Hengstebeck’s promotions; he did not file or amend charges alleging retaliation or hostile work environment. Defendants moved for summary judgment; the court granted it in full.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are individual managers liable under Title VII/ADEA for retaliation/hostile work environment?	Smith and Huffman are liable for retaliatory/harassing acts they conducted.	Individual employees are not employers under Title VII/ADEA and thus not liable.	Dismissed claims against Smith and Huffman — no individual liability under Title VII/ADEA.
Are Cotton’s race and age discrimination claims timely (EEOC exhaustion/300‑day rule)?	Cotton contends Soop’s 2015 promotion was new and was first learned via March 12, 2015 email, so his Dec 23, 2015 EEOC charge is timely for 2015 acts.	Most alleged discriminatory acts occurred before Feb 26, 2015 (outside 300 days); Cotton knew of Soop’s promotion by Jan/Feb 2015, so charge is untimely.	Claims of race and age discrimination are time‑barred for events before Feb 26, 2015; all discrimination claims dismissed as untimely.
Did Cotton exhaust administrative remedies for retaliation claims?	Retaliation claims can reasonably grow out of the EEOC charge and post‑charge acts are encompassed.	Cotton did not amend or file a new EEOC charge alleging retaliation; exhaustion is lacking.	Court questioned exhaustion argument but decided summary judgment on other grounds; did not rely solely on exhaustion.
Can Cotton establish a prima facie case of retaliation (adverse action, causation)?	Post‑charge conduct (emails, counseling, removal from mailing list, supervisor disputes, wrongful terminations of staff) amounts to materially adverse actions and shows causal link via temporal proximity.	The cited actions are trivial/petty or not materially adverse; temporal gap (~4 months) weakens causal inference and no other evidence of causation exists.	Cotton failed to show a materially adverse action or sufficient causal connection; retaliation/hostile work environment claims dismissed.

Key Cases Cited

Wathen v. General Electric Co., 115 F.3d 400 (6th Cir. 1997) (individuals are not employers under Title VII)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard and burden)
National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (administrative exhaustion and timely EEOC charge rule)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for discrimination/retaliation claims)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (retaliation: materially adverse action standard)
Michael v. Caterpillar Fin. Servs. Corp., 496 F.3d 584 (6th Cir. 2007) (elements of prima facie retaliation case)
Smith Wholesale Co. v. R.J. Reynolds Tobacco Co., 477 F.3d 854 (6th Cir. 2007) (view evidence in light most favorable to nonmovant on summary judgment)
Mickey v. Zeidler Tool & Die Co., 516 F.3d 516 (6th Cir. 2008) (temporal proximity and causation in retaliation cases)