Haworth v. Tronox Holdings PLC
5:22-cv-00606-PRW
W.D. Okla.Sep 26, 2023Background
- Tronox hired Susan Haworth in 2017 as a Credit/Cash Analyst in Oklahoma City; in Spring 2020 Tronox implemented a corporate restructuring and a reduction-in-force (RIF) while moving headquarters to Stamford, CT.
- Tronox eliminated 5 of 7 Finance/Accounting positions in Oklahoma City, including Haworth’s; Tronox says it eliminated her because her duties did not require a full‑time role.
- Two younger coworkers (Staci McPherson, age 41, and Julia Sweet, under 40) were offered new roles during the RIF; Haworth was not.
- Haworth claims age discrimination and retaliation under the ADEA and OADA; Tronox moved for summary judgment.
- Evidence cited by Haworth included reassignment of duties to higher‑paid employees, a CEO remark about needing “new, younger employees,” a LinkedIn post by McPherson, and past layoffs affecting older workers; Haworth admitted she never complained about age discrimination before termination.
- The court found Haworth could make a prima facie discrimination showing but failed to show Tronox’s proffered nondiscriminatory reason was pretextual; the court also found Haworth failed to establish retaliation and granted summary judgment for Tronox.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Age discrimination (ADEA/OADA) | Haworth was terminated because of her age | Position eliminated because duties did not justify full‑time role | Court: Haworth established prima facie (younger employees treated more favorably) but failed to prove pretext; summary judgment for Tronox |
| Pretext of nondiscriminatory reason | Reassignment of duties to higher‑paid employees, EEOC statement, CEO remark, LinkedIn post, pattern of older layoffs show pretext | Tronox offered a specific, consistent business reason (job didn’t require full time); EEOC statement did not assert poor performance | Court: evidence insufficient to create genuine dispute about pretext; employer decision not shown to be age‑based |
| Retaliation (ADEA/OADA) | (Asserted) adverse action was in retaliation for protected opposition | Haworth never engaged in protected opposition; no evidence of complaint | Court: Haworth admitted she never complained; failed prima facie retaliation element; summary judgment for Tronox |
| Use of co‑worker comparisons in RIF | McPherson and Sweet were younger and got new roles; supports inference of age bias | Those employees were differently situated/better qualified | Court: comparisons suffice for prima facie inference but do not overcome failure to prove pretext |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant’s burden on summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (requiring more than metaphysical doubt to defeat summary judgment)
- Scott v. Harris, 550 U.S. 372 (2007) (court may disregard contrived factual disputes blatantly contradicted by record)
- Jones v. Oklahoma City Public Schools, 617 F.3d 1273 (10th Cir. 2010) (McDonnell Douglas framework and pretext standards)
- Beaird v. Seagate Tech., 145 F.3d 1159 (10th Cir. 1998) (RIF and comparator analysis)
- Jaramillo v. Colorado Judicial Dep’t, 427 F.3d 1303 (10th Cir. 2005) (pretext—weaknesses, inconsistencies, contradictions standard)