HARRIS v. CARRIER CORPORATION
1:15-cv-01952
| S.D. Ind. | Mar 23, 2017Background
- Pamela Harris, an African American woman over 40, worked at Carrier since 2005 in a male‑dominated skilled trade role and trained toward Journeyman status but lacked final certification.
- She alleges persistent sex‑based harassment (demeaning comments, exclusion from training, unfavorable work assignments, false discipline) and retaliation after reporting safety concerns.
- Harris suffered a workplace shoulder injury that led to medical restrictions and leave; she alleges Carrier assigned tasks violating restrictions and later failed to accommodate her return until placing her in a different role (Inspector).
- She filed two EEOC charges (received right‑to‑sue letters) and sued Carrier in federal court asserting sex, race, age, disability discrimination, and retaliation; she later dropped race and age claims.
- Carrier moved to dismiss four claims; the court considered whether Harris’ disability discrimination and retaliation claims survive a Rule 12(b)(6) challenge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of disability discrimination claim | Harris alleges disparate treatment based on her shoulder injury and that Carrier made prohibited medical inquiries; she is not pursuing a failure‑to‑accommodate theory | Carrier says allegations are conclusory, fail to plead she was qualified for the job with/without accommodation, and some allegations post‑date EEOC charges (failure to exhaust) | Denied dismissal: court finds claim not implausible at pleading stage given EEOC charge referenced medical‑inquiry allegations |
| Sufficiency of retaliation claim | Harris alleges protected activity (filing EEOC charges) and subsequent harassment/adverse acts | Carrier argues complaint is conclusory and that some alleged protected activity (reporting safety violations) is not statutorily protected; Carrier also notes waiver of response | Denied dismissal: court holds filing an EEOC charge is protected activity and complaint plausibly alleges adverse actions and causation at pleading stage |
| Scope of claims relative to EEOC charges | Harris’ EEOC charge referenced prohibited medical inquiries under the ADA | Carrier contends some alleged misconduct (post‑EEOC) falls outside scope and thus unexhausted | Court treats EEOC charges as encompassing medical‑inquiry allegation and declines dismissal at pleadings stage |
| Dismissal of race and age claims | Harris voluntarily narrowed claims in her Statement of Claims | Carrier sought dismissal of those claims | Court denies as moot because Harris abandoned race and age claims |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (pleading standard: short and plain statement)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (conclusory allegations insufficient)
- Manning v. Miller, 355 F.3d 1028 (motions to dismiss should not be granted if any set of facts could entitle plaintiff to relief)
- Conner v. Illinois Dep’t of Nat. Res., 413 F.3d 675 (EEOC charge exhaustion and scope rule)
- Tomanovich v. City of Indianapolis, 457 F.3d 656 (filing EEOC charge is protected activity for retaliation)
- Boston v. U.S. Steel Corp., 816 F.3d 455 (elements of retaliation claim)