James Pierson v. Quad/Graphics Printing Corp.
2014 U.S. App. LEXIS 7277
| 6th Cir. | 2014Background
- Plaintiff James Pierson, 62, was Plant Facilities Manager at QG’s Dickson, TN plant and had long, satisfactory performance history; he was terminated August 23, 2011.
- QG executives had initiated a company‑wide cost‑cutting "Fortress Quad" review directing managers to identify positions that could be eliminated.
- Regional manager Carl Lentz selected Pierson for discharge; corporate executive Joe Muehlbach approved the termination. HR used a reduction‑in‑force script and completed "Criteria for Selection" forms after the decision.
- After termination, David DePriest (47), an energy‑procurement/capital‑projects manager based elsewhere, began spending most of his time at Dickson, moved his office there, and assumed many Facilities Manager duties. QG maintained DePriest retained his prior duties as well.
- District court granted summary judgment for QG, finding Pierson was terminated as part of a bona fide reduction in force; Sixth Circuit reversed and remanded, finding genuine fact disputes about whether Pierson’s job was eliminated or replaced and whether the RIF was pretextual.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pierson was terminated as part of a reduction in force or replaced by a younger employee | Pierson contends DePriest effectively replaced him (assumed duties, moved to Dickson), so his job was not eliminated | QG contends position was eliminated under company‑wide RIF and duties redistributed; DePriest retained prior duties | Genuine dispute exists; jury could find DePriest replaced Pierson, so RIF characterization is contested |
| Whether Pierson made a prima facie ADEA/THRA case | Pierson argues he is over 40, was qualified, suffered adverse action, and job went to a younger employee | QG argues heightened RIF standard applies and Pierson didn’t show he was singled out or replaced | Court held Pierson presented sufficient evidence to avoid heightened RIF standard and establish prima facie case |
| Whether QG’s stated RIF reason is legitimate or pretextual | Pierson argues pretext: shifting justifications, decision‑maker inconsistency, and evidence DePriest replaced him | QG argues a broad, documented RIF motivated the decision and performance was not determinative | Court held there is sufficient evidence of pretext (shifting justifications, decision‑maker questions) to create triable issues |
| Whether summary judgment was appropriate | Pierson asks reversal and remand for trial | QG asks affirmance of district court summary judgment | Sixth Circuit REVERSED summary judgment and REMANDED for further proceedings |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discriminatory discharge claims)
- Gross v. FBL Financial Services, Inc., 557 U.S. 167 (plaintiff must show but‑for causation in ADEA claims)
- Barnes v. GenCorp, 896 F.2d 1457 (6th Cir.) (explaining when RIF and replacement analyses apply)
- Sahadi v. Reynolds Chemical, 636 F.2d 1116 (6th Cir.) (distinguishing elimination from replacement where duties assumed in addition to other work)
- Blair v. Henry Filters, Inc., 505 F.3d 517 (6th Cir.) (prima facie elements for age discrimination)
- Geiger v. Tower Automotive, 579 F.3d 614 (6th Cir.) (RIF/replacement analysis and summary judgment standards)
- Wexler v. White’s Fine Furniture, Inc., 317 F.3d 564 (6th Cir.) (tests for proving pretext)