Joseph Casias v. Wal-Mart Stores, Inc.
695 F.3d 428
| 6th Cir. | 2012Background
- Casias, a Wal-Mart employee in Battle Creek, was terminated in 2009 after a positive marijuana test.
- Casias held a Michigan MMMA registry card and used marijuana at home for medical reasons; he alleges this complied with state law.
- Wal‑Mart’s drug policy led to termination; Estill, the store manager, communicated the termination under direction from corporate headquarters.
- Casias and Estill are Michigan residents; the case was removed to federal court based on diversity, with Estill alleged to be improperly joined.
- District court found Estill was fraudulently joined and dismissed, and it held MMMA does not regulate private employment—Plaintiff appealed.
- Court affirms district court, concluding MMMA does not regulate private employment and Estill cannot be liable for wrongful discharge under Michigan law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Estill was fraudulently joined to defeat diversity | Casias argues Estill participated in termination and is improperly joined | Estill had no role in the termination decision and cannot be liable | Estill not liable; fraudulant-joinder finding supported; remand not required |
| Whether MMMA regulates private employment regarding disciplinary actions | MMMA bars disciplinary action against cardholders using marijuana lawfully | MMMA applies to state actions, not private employment | MMMA does not regulate private employment; private employers may discipline for marijuana use |
| Whether MMMA provides a defense to wrongful discharge in private employment | MMMA offers private‑employment protections against discipline | No such private-employment restriction in MMMA | MMMA does not provide a private-employment defense; no implied limitation on at‑will employment |
Key Cases Cited
- Coyne v. American Tobacco Co., 183 F.3d 488 (6th Cir. 1999) (fraudulent joinder standard in remand context)
- Alexander v. Electronic Data Sys. Corp., 13 F.3d 940 (6th Cir. 1994) (colorable basis for predicting liability; standard for fraudulent joinder)
- Triggs v. John Crump Toyota, Inc., 154 F.3d 1284 (11th Cir. 1998) (fraudulent joinder considerations; standard relied upon)
- Delcamp Truck Ctr., Inc. v. Citizens Ins. Co., 178 Mich.App. 570, 444 N.W.2d 210 (1989) (personal liability of corporate actors where actively participated in torts)
- Trail Clinic, P.C. v. Bloch, 114 Mich.App. 700, 319 N.W.2d 638 (1982) (personal liability for acts by officers/agents of corporation)