Everett Chattman v. Toho Tenax America, Inc.
2012 U.S. App. LEXIS 14359
| 6th Cir. | 2012Background
- Chattman, African American, worked 20 years as shipping coordinator at Toho in Rockwood, TN.
- Tullock, a Caucasian former HR Director, allegedly made racist comments indicating bias against African Americans.
- On Oct. 2, 2007, horseplay incident between Chattman and a white coworker led to investigation and suspension.
- Chattman received a final written warning on Dec. 20, 2007, which made him ineligible for promotions for one year.
- Chattman alleged Tullock’s racial animus motivated the disciplinary action; district court granted summary judgment finding no prima facie case or pretext.
- District court ruling reversed and remanded for trial under direct/circumstantial evidence framework and Staub cat’s-paw doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Direct vs circumstantial evidence of discrimination | Chattman has direct evidence via racist statements | Discrimination must be shown under McDonnell Douglas framework | Direct evidence supported; or at least triable issue under Staub guidance |
| Prima facie case elements for race discrimination | Discipline changed terms; comparable white employees not disciplined | Final warning a legitimate nondiscriminatory reason | Genuine dispute as to whether comparable white horseplay cases were treated similarly |
| Cat’s-paw v. Staub causation | Tullock’s animus proximate to Chattman’s discipline via intermediates | Investigation independent; no direct link to ultimate action | Staub-based causation applies; summary judgment improper; liability could attach |
| Proximate cause of adverse action | Tullock intended and caused adverse action | Independent investigation could sever liability | Evidence creates factual question whether biased input proximate to decision |
| Scope of liability for intermediate biases | Toho liable for discriminatory conduct via cat’s paw | Independent investigation absolves or limits liability | Staub permits imputation where biased input informs decisionmaking; reasonable jury could decide |
Key Cases Cited
- Talley v. Bravo Pitino Rest., 61 F.3d 1241 (6th Cir. 1995) (direct evidence from racist statements indicates discriminatory intent)
- DiCarlo v. Potter, 358 F.3d 408 (6th Cir. 2004) (direct evidence vs circumstantial; framework for discrimination)
- Madden v. Chattanooga City Wide Serv. Dept., 549 F.3d 666 (6th Cir. 2008) (causal nexus and biased information to senior management)
- Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (6th Cir. 1998) (influence of biased intermediate employee on decisionmaker)
- Staub v. Proctor Hospital, 131 S. Ct. 1186 (Supreme Court 2011) (cat’s-paw liability; imputes discriminator’s animus to employer)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (framework for circ. evidence discrimination)
- Ricc i v. DeStefano, 557 U.S. 557 (U.S. 2009) (discrimination analysis in Title VII context)