Douglas v. International Automotive Components Group North America, Inc., 5:10-cv-10372

Douglas, age 57, was laid off from IAC’s Huron, Ohio plant on Jan 30, 2009 as part of a 2009 RIF.
IAC acquired Lear assets in 2007 and Collins & Aiken assets in 2008, expanding EVA and NVH projects at the Huron plant.
Douglas worked in quality engineering/lab management; Starling, age 36, joined from C&A and focused on carpet EVA; Raymont favored Starling for the carpet project.
IAC decided to manufacture EVA at the Huron plant, creating two EVA formulas: NVH for dashboards and a carpet-coating EVA.
Raymont retained Starling over Douglas due to Starling’s critical role in the carpet EVA project, leading to Douglas’s temporary layoff that became permanent on Mar 31, 2009.
Following the layoff, 10 employees at Huron were laid off (8 were over 40); Douglas applied for other positions but was not hired.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Douglas replaced by someone outside the protected class?	Douglas argues Starling replaced him.	Starling absorbed duties but did not replace Douglas.	No replacement; RIF reduction; no prima facie evidence of age discrimination.
Did IAC discriminate in hiring when Douglas was not chosen for positions?	Douglas contends he was more qualified than Dietz/Hertlein.	Dietz and Hertlein were not similarly situated; Adecco processing unclear.	No prima facie case; no evidence of discriminatory hiring decision.

Geiger v. Tower Automotive, 579 F.3d 614 (6th Cir. 2009) (prima facie RIF burden and replacement analysis guidance)
Brocklehurst v. PPG Indus., Inc., 123 F.3d 890 (6th Cir. 1997) (discrimination in RIF requires more than a better older employee being fired)
Barnes v. GenCorp, Inc., 896 F.2d 1457 (6th Cir. 1990) (pretext in RIF requires stronger showing when qualifications are similar)
Bender v. Hecht’s Dept. Stores, 455 F.3d 612 (6th Cir. 2006) (qualifications evidence must show significant disparity or call honesty of explanation into question)
Browning v. Department of the Army, 436 F.3d 692 (6th Cir. 2006) (employer’s decision evaluated by the decisionmaker’s perception of qualifications)
Hartsel v. Keys, 87 F.3d 795 (6th Cir. 1996) (employers may hire/fire for permissible reasons even if others disagree)
Simpson v. Midland-Ross Corp., 823 F.2d 937 (6th Cir. 1987) (small sample sizes in statistics must still show significant disparity)
Seay v. Tennessee Valley Authority, 339 F.3d 454 (6th Cir. 2003) (elements of failure-to-hire prima facie case)