Karen Hrapkiewicz v. Board of Governors of Wayne State University
330189
| Mich. Ct. App. | Mar 9, 2017Background
- Plaintiff (Hrapkiewicz) sued Wayne State University Board of Governors for age discrimination after being terminated.
- The termination arose from plaintiff allowing students to take an exam on a closed campus; defendants also cited related misconduct incidents.
- At summary disposition and again at trial (directed verdict motion), the issue was whether plaintiff established a prima facie case of age discrimination under McDonnell Douglas burden-shifting.
- The majority found plaintiff met the prima facie case; Judge Servitto dissented, arguing plaintiff failed to show age was a motivating factor.
- Decisionmakers who recommended termination included one three years younger than plaintiff and one roughly 13 years older; no evidence showed age was discussed or influenced the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff established a prima facie age-discrimination claim under McDonnell Douglas/Hazle | Plaintiff argued she belonged to protected class, suffered adverse action, was qualified, and was replaced by a younger person, creating an inference of discrimination | Defendant argued plaintiff presented no evidence age was a factor; replacement’s age alone is insufficient; decisionmakers didn’t consider age | Dissent: plaintiff failed to establish prima facie case because no evidence age motivated the termination |
| Whether birthdates alone can satisfy the fourth prima facie element (inference of discrimination) | Birthdates and younger replacement suffice to raise an inference | Birthdates alone do not create an inference; must show circumstances permitting an inference that age influenced the decision | Dissent: circumstances here did not give rise to an inference of discrimination |
| Proper role of pretext at summary-judgment stage | Plaintiff treated defendant’s stated reason for termination as subject to pretext analysis | Defendant argued pretext is considered only after a prima facie case is established | Dissent: trial court erred by treating pretext before prima facie was shown |
| Whether directed verdict should have been granted at trial | Plaintiff argued sufficient evidence at trial to let jury decide whether age was a motivating factor | Defendant argued no evidence at trial showed age was a factor, warranting directed verdict | Dissent: would have granted directed verdict for defendant due to lack of evidence of age-based motive |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (established burden-shifting framework for discrimination cases)
- DeBrow v. Century 21 Great Lakes, Inc., 463 Mich. 534 (2001) (McDonnell Douglas framework applies when only circumstantial evidence of discrimination exists)
- Lytle v. Malady, 458 Mich. 153 (1998) (sets forth prima facie elements for age discrimination claims)
- Town v. Michigan Bell Tel. Co., 455 Mich. 688 (1997) (discusses modified McDonnell Douglas prima facie test for age/sex discrimination)
- Hazle v. Ford Motor Co., 464 Mich. 456 (2001) (clarifies fourth prima facie element requires circumstances giving rise to an inference that protected characteristic was a motivating factor)