Daryl Scruggs v. Carrier Corporatio
688 F.3d 821
| 7th Cir. | 2012Background
- Carrier hired a private investigator to surveil about 35 employees for alleged FMLA abuse at its Indianapolis plant.
- Scruggs, authorized for intermittent FMLA leave to care for his mother, was observed on surveillance day July 24, 2007; video suggested he did not leave his home.
- Scruggs provided documentation (nursing home letter, sign-out sheet, doctor notes) claiming he assisted his mother on July 24, which Carrier found inconsistent.
- Carrier terminated Scruggs for violating Plant Rule 10 (falsifying company documents) after considering surveillance and documentation.
- Scruggs sued in state court for interference and retaliation under the FMLA; case removed to federal court and cross-motions for summary judgment were filed.
- The district court granted summary judgment in Carrier’s favor, holding there was an honest suspicion Scruggs misused his FMLA leave.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Interference: did Carrier interfere with Scruggs's FMLA rights by terminating him? | Scruggs: termination denied his FMLA benefits. | Carrier: termination based on honest suspicion of abuse, not retaliatory. | No interference; honest-suspicion defense defeats claim. |
| Retaliation: did Scruggs prove a causal link between protected activity and termination? | Scruggs asserts termination was due to taking FMLA leave. | Carrier lacked causal connection; termination followed investigation findings, not protected activity. | No direct evidence of discrimination; no actionable retaliation. |
| Sufficiency of evidence for honest-suspicion standard to defeat FMLA claim | Carrier should have conducted a more thorough investigation; videos and documents were insufficient to find abuse. | Video plus documents provided ample basis for honest suspicion. | Evidence supported honest suspicion; district court's reliance on it was proper. |
Key Cases Cited
- Crouch v. Whirlpool Corp., 447 F.3d 984 (7th Cir. 2006) (honest-suspicion standard defeats FMLA claim)
- Vail v. Raybestos Prods. Co., 533 F.3d 904 (7th Cir. 2008) (honest suspicion supports non-interference)
- Kariotis v. Navistar Int'l Transp. Corp., 131 F.3d 672 (7th Cir. 1997) (investigation can rely on suspicion and videotape to justify termination)
- Burnett v. LFW Inc., 472 F.3d 471 (7th Cir. 2006) (direct evidence of retaliation required; protected activity not clearly connected here)