Debano-Griffin v. Lake County
493 Mich. 167
| Mich. | 2013Background
- Debano-Griffin served as Lake County 911 director since 1998; millage funded ambulance service with Life EMS and county operations.
- In Sept 2004, $50,000 was transferred from the ambulance fund to the 911 account for a
- mapping project,
- which Debano-Griffin objected to as violating the millage and grant constraints.
- Nov 10, 2004, the board merged two county positions, eliminating Debano-Griffin's 911 director role; she received termination notice Dec 22, 2004 stating budget-cut reasons.
- As of Oct 29, 2004, the county budget proposed for 2005 showed the 911 director position fully funded.
- January 2005 Debano-Griffin filed a WPA claim; trial court denied summary disposition, jury awarded verdict for plaintiff; appellate history included reversals and remands before the Supreme Court decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether causation under WPA is shown by more than a temporal link. | Debano-Griffin showed a 12‑day funding shift after protected activity. | A temporal relationship alone cannot prove causation. | Yes; causation shown; prima facie case established. |
| Whether defendants’ budget justification was pretext for retaliation. | Budget grounds lacked factual basis and showed retaliatory motive. | Budget rationale was legitimate and not a pretext. | Triable issue on pretext; summary disposition improper. |
| Whether WPA claims may be reviewed despite business judgment and separation‑of‑powers concerns. | Judicial review of budgetary motives is permissible under WPA. | Review would intrude on legislative business and violate separation of powers. | WPA waives legislative immunity; judicial review permissible; separation of powers not violated. |
Key Cases Cited
- Hazle v Ford Motor Co, 464 Mich 456 (2001) (McDonnell Douglas framework in WPA claims; business judgment not controlling)
- West v Gen Motors Corp, 469 Mich 177 (2003) (temporal relation alone not enough for causation; need more)
- Shallal v Catholic Social Servs of Wayne Co, 455 Mich 604 (1997) (McDonnell Douglas burden-shifting framework applies to WPA claims)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for anti-retaliation claims)
- Bogan v. Scott-Harris, 523 U.S. 44 (1998) (legislative immunity and nature of act for immunity analysis)
- Anzaldua v Band, 457 Mich 530 (1998) (WPA waiver of legislative immunity; applicability to public employers)