Hackney v. LaFontaine Automotive Group, LLC
2:22-cv-12612
E.D. Mich.Aug 28, 2025Background
- Samuel Hackney filed a lawsuit against his former employer, LaFontaine Chrysler Dodge Jeep Ram of Clinton, Inc., alleging retaliation in violation of Title VII and the Michigan ELCRA.
- The basis of Hackney's claim was his alleged protected activity: responding to a supervisor’s use of an ethnic slur with, “Do you know I’m Lebanese?”
- The Court originally granted summary judgment to LaFontaine, finding that although Hackney established a prima facie case of retaliation, LaFontaine articulated a legitimate, non-retaliatory reason for the termination.
- Hackney moved for reconsideration, asserting clear legal error, mainly on the grounds of the decisionmaker identity and the cat’s paw doctrine applicability.
- The Court denied the motion for reconsideration, holding that no material factual dispute existed on who made the termination decision, and Hackney's alleged protected activity did not meet the legal threshold.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Decisionmaker identity (cat’s paw doctrine) | Riley was the ultimate decisionmaker, so cat’s paw does not apply; factual dispute exists. | Berghoefer had final authority; Riley only involved. | No genuine factual dispute; Berghoefer was the decisionmaker. |
| Sufficiency of evidence for jury | Evidence (termination letter, discovery responses) shows jury question as to who decided termination. | Evidence shows only involvement, not ultimate authority, of Riley and others. | Evidence insufficient for a reasonable jury to find otherwise. |
| Cat’s paw doctrine applicability | Not required if Riley made the decision; even so, should survive summary judgment. | Riley’s animus not shown to be but-for cause of termination; no proximate causation. | Cat’s paw doctrine correctly applied; Hackney did not meet standard. |
| Protected activity under Title VII / ELCRA | Hackney’s response to slur was protected activity. | Single, vague complaint does not constitute protected opposition under the law. | Single complaint not protected activity under precedent. |
Key Cases Cited
- Exxon Shipping Co. v. Baker, 554 U.S. 471 (standard for Rule 59(e) motions; motion not to relitigate old matters)
- Staub v. Proctor Hosp., 562 U.S. 411 (established cat’s paw theory for imputing bias)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard – genuine dispute of material fact)
- Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (isolated complaints about a single instance do not constitute protected activity)