Dawn Hayes v. Clariant Plastics & Coatings USA, Inc.
24-1336
| 6th Cir. | Jul 18, 2025Background
- Dawn Hayes worked for Clariant Plastics & Coatings USA, Inc. for 25 years as a warehouse logistics clerk and was promoted to senior logistics clerk in 2015.
- In 2017, Clariant implemented a new SAP software system and later created a new warehouse coordinator position, filled by Chris Perjesi.
- In 2018, Clariant initiated a workforce reduction; Hayes was the only woman among five warehouse employees. She was selected for termination despite having high performance reviews and seniority.
- Hayes alleged pervasive sexual harassment during her employment and unequal pay compared to male colleagues.
- After her termination, Hayes filed an EEOC charge and then sued in federal court for gender and age discrimination, unequal pay, and hostile work environment.
- The district court granted summary judgment for Clariant on all claims; this opinion reviews that decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Age discrimination | Terminated due to age; treated less favorably than younger comparators | Termination based on neutral workforce reduction; comparators not relevant | No evidence of less favorable treatment due to age; summary judgment for Clariant |
| Gender discrimination | Terminated due to gender; similarly situated male retained | Workforce reduction based on skills; male comparator not similarly situated | Hayes showed factual dispute; summary judgment reversed; remanded for trial |
| Unequal pay | Performed equal work as male coworker but paid less | Different responsibilities and skills justify pay differential | Sufficient similarity in work; summary judgment reversed; remanded for trial |
| Hostile work environment | Suffered persistent sexual harassment; forms part of EEOC claim | Not properly exhausted in EEOC or timely; acts predate limitation period | Claim was time-barred and/or not properly exhausted; summary judgment for Clariant |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
- Grosjean v. First Energy Corp., 349 F.3d 332 (defines protected class and comparator standards for age discrimination)
- Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (standard for similarly situated comparators in discrimination cases)
- Risch v. Royal Oak Police Dep’t, 581 F.3d 383 (probative value of discriminatory atmosphere evidence in discrimination claims)
- Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (discusses continuing violation doctrine for Title VII time-bar analysis)
- Alexander v. Gardner-Denver Co., 415 U.S. 36 (exhaustion of administrative remedies under Title VII)
- Beck-Wilson v. Principi, 441 F.3d 353 (standards for Equal Pay Act claims and burden of proof shift)