John Woods v. City of Berwyn
803 F.3d 865
| 7th Cir. | 2015Background
- John Woods, a Berwyn Fire Department lieutenant, was alleged to have told a coworker (Lt. Ronald Hamilton) he wanted to "kill somebody, all of them" and that his children would "tune them up." Hamilton reported the conversation to Chief Denis O’Halloran.
- O’Halloran ordered a wellness check and a psychological evaluation (which found no risk); he nonetheless issued a Statement of Charges seeking Woods’s termination for, inter alia, disorderly conduct and false statements.
- The Board of Fire and Police Commissioners held a full adversarial hearing with counsel, witnesses, cross-examination, exhibits, and rulings on objections; Woods was represented. The Board credited Hamilton’s testimony, found cause, and terminated Woods. State courts later upheld the Board’s decision.
- Woods sued in federal court asserting FMLA retaliation, ADA and ADEA discrimination, and Workers’ Compensation Act retaliation, relying principally on a cat’s paw theory (that O’Halloran’s alleged bias was imputed to the Board).
- The district court granted summary judgment for the City; the Seventh Circuit affirmed, concluding the Board’s independent, adversarial hearing broke the causal chain from any alleged subordinate bias to the termination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a subordinate’s alleged discriminatory animus (O’Halloran) can be imputed to an unbiased ultimate decision-maker (Board) under the cat’s paw theory | Woods: O’Halloran set the termination process in motion and his recommendation should be imputed despite the Board hearing | City: The Board conducted an independent, adversarial hearing and relied on Hamilton’s testimony, not O’Halloran’s report | The Board’s full hearing and reliance on non-biased testimony broke the causal chain; cat’s paw liability fails |
| Whether the Board was merely a rubber stamp for management | Woods: Board historically adopted management recommendations and O’Halloran controlled discipline, so the Board was not independent | City: The record shows the Board had authority and conducted a meaningful adjudication; isolated past adoptions do not show rubber-stamping | Court: No genuine issue that the Board rubber-stamped here; insufficient evidence to infer lack of independence |
| Whether Woods identified a proper comparator for discrimination claims | Woods: Implied that others treated differently | City: No similarly situated employee who engaged in comparable threatening conduct and was treated more favorably | Court: Woods failed to identify a proper comparator; absence supports summary judgment |
| Whether pretext issues prevent summary judgment | Woods: Contends statements attributed to him might be false and decisions pretextual | City: Independent Board findings negate reliance on O’Halloran; termination supported by credible testimony | Court: Because Woods failed to establish prima facie cat’s paw liability, court did not reach pretext; summary judgment affirmed |
Key Cases Cited
- Staub v. Proctor Hosp., 562 U.S. 411 (2011) (adopted cat’s paw theory; subordinate bias can be a proximate cause unless independent investigation severs causal chain)
- Matthews v. Waukesha Cnty., 759 F.3d 821 (7th Cir. 2014) (describes cat’s paw: biased subordinate uses decision-maker as dupe)
- Schandelmeier-Bartels v. Chicago Park Dist., 634 F.3d 372 (7th Cir. 2011) (causal chain can be broken by meaningful, independent investigation)
- Nichols v. Michigan City Plant Planning Dept., 755 F.3d 594 (7th Cir. 2014) (summary judgment standards; view facts in light most favorable to nonmovant)
- Lacks v. Ferguson Reorganized Sch. Dist. R-2, 147 F.3d 718 (8th Cir. 1998) (full hearing and multiple witnesses can constitute independent investigation breaking causation)
- Romans v. Michigan Dep’t of Human Servs., 668 F.3d 826 (6th Cir. 2012) (independent investigation that verifies facts and does not rely on biased source negates subordinate-bias liability)
- Lobato v. N.M. Env’t Dept., 733 F.3d 1283 (10th Cir. 2013) (employer liability absent if employer independently verifies facts and does not rely on biased subordinate)