Jones v. Ford Motor Company, 1:13-cv-02809

Background

Roy Jones, hired by Ford in 1985, was a salaried, non-union Senior Process Coach supervising ~20 hourly employees at Ford’s Walton Hills stamping plant; he was 59 at termination.
Jones had a lengthy disciplinary history for verbal harassment and safety-related issues, including multiple suspensions and documented counseling.
December 2012: investigated for allegedly insulting and making threatening gestures toward a co-worker; suspended four weeks.
May 2, 2013: Jones borrowed an hourly employee’s personal lock to enter an automation cell and entered without a required bump cap, violating Ford’s ECPL and PPE safety policies; Ford investigated and concluded the violations were ‘‘flagrant.’’
Ford terminated Jones on June 7, 2013; he was replaced by a 62-year-old. Jones sued in Ohio state court asserting age discrimination (R.C. § 4112.02(A)), wrongful termination/public policy, and intentional infliction of emotional distress; case removed to federal court.
The Court considered Ford’s motion for summary judgment and granted it in full.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jones was terminated because of age (discriminatory discharge under R.C. § 4112.02(A))	Jones claims termination was age-based and points to promotional/transfer circumstances and alleged disparate treatment comparators.	Ford argues Jones cannot make a prima facie case: replacement was older and no similarly situated younger employee received better treatment; also no direct evidence of age animus.	Court: Summary judgment for Ford — Jones failed to show similarly situated younger comparator or direct evidence of age-based motive.
Whether Ford discriminated by failing to offer Jones transfer opportunities after plant closure was announced	Jones asserts he was denied transfers due to age.	Ford contends this claim was not pled and was raised first in opposition to summary judgment; thus Ford lacked notice and opportunity to pursue discovery.	Court: Claim not plead; Jones did not amend complaint — summary judgment for Ford on failure-to-transfer claim.
Whether Jones’s claims for wrongful termination (public policy) and intentional infliction of emotional distress survive	Jones included these claims in the complaint.	Ford argued Jones abandoned these claims by not addressing them in his summary judgment opposition.	Court: Jones abandoned both claims by failing to oppose — summary judgment for Ford.
Whether summary judgment standard was met	N/A (procedural)	Ford maintained record showed no genuine dispute of material fact supporting discrimination or other claims.	Court: Applying Rule 56 and applicable precedent, Court found no triable issue and granted summary judgment to Ford.

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (movant need not negate opponent’s claim; show absence of an essential element).
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment standard and evaluating reasonable jury inference).
Adickes v. S.H. Kress & Co., 398 U.S. 144 (1970) (plaintiff’s burden to produce evidence creating genuine dispute).
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for circumstantial discrimination evidence).
Gross v. FBL Financial Servs., Inc., 557 U.S. 167 (2009) (plaintiff must prove but-for causation for age discrimination).
Wexler v. White’s Fine Furniture, Inc., 317 F.3d 564 (6th Cir. 2003) (definition of direct evidence of discrimination).
Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (6th Cir. 1998) (elements for ADEA/age-discrimination prima facie case and transfer claim).
Geiger v. Tower Auto., 579 F.3d 614 (6th Cir. 2009) (elements for circumstantial age-discrimination prima facie case).