Lane v. Riverview Hospital
2016 U.S. App. LEXIS 15822
| 7th Cir. | 2016Background
- Chris Lane, an African American security guard at Riverview Hospital since 1999, resigned in 2012 after the hospital told him he would be fired for slapping an autistic patient who had been violent and spat at him.
- Hospital HR director Ann Kuzee investigated, concluded the slap violated policies (restraints/violence), recommended termination, and the Executive Steering Committee approved conditional on Sheriffs Department input; a sheriff’s major said the slap was inappropriate.
- Lane filed reports (hospital and Sheriffs Department); prosecutors declined criminal charges but the Sheriffs Department thought Lane overreacted.
- Lane sued under Title VII and § 1981 for race discrimination, relying on a ‘‘convincing mosaic’’ of circumstantial evidence rather than McDonnell Douglas framework.
- Evidence Lane offered: (1) a purportedly similar incident involving white nurse Matt Rainey who was not disciplined; (2) an allegedly false EEOC statement that Kuzee was unaware of the Rainey incident; (3) one comment by Kuzee referencing race in an unrelated theft dispute; (4) one question by Kuzee about the race of a boy in a story Lane told.
- The district court granted summary judgment for the hospital; the Seventh Circuit affirmed, concluding the circumstantial evidence was insufficient to permit a reasonable jury to infer racial discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether termination/constructive discharge was discriminatory | Lane: a "convincing mosaic" of circumstantial facts permits inference of race-based firing | Riverview: termination was a legitimate response to admitted misconduct; no evidence of racial animus | Affirmed: insufficient circumstantial evidence to create a triable issue |
| Whether Rainey incident is a valid comparator | Lane: Rainey (white) engaged in similar conduct but was not disciplined, supporting disparate treatment | Riverview: facts differ; Rainey denied wrongdoing and investigators credited him; decision-makers differed | Not sufficiently similar from Kuzee’s perspective; comparator fails |
| Whether Kuzee’s inaccurate EEOC statement supports inference of pretext | Lane: misrepresentation about Kuzee’s knowledge of Rainey shows dishonesty and pretext | Riverview: statement was a mistake or immaterial; even deliberate misstatement alone doesn't prove discriminatory motive | Even if deliberate, alone it does not permit reasonable inference of race discrimination |
| Whether Kuzee’s race-related remarks support discriminatory intent | Lane: one prior remark and one question indicate bias | Riverview: remarks were non-hostile, context-neutral, and not reflective of animus toward Lane | Remarks were stray/neutral and do not support an inference of discriminatory intent |
Key Cases Cited
- Mintz v. Caterpillar Inc., 788 F.3d 673 (7th Cir. 2015) (summary-judgment review standard; view evidence in non-movant’s favor)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (framework for burden-shifting in discrimination cases)
- Castro v. DeVry Univ., Inc., 786 F.3d 559 (7th Cir. 2015) ("convincing mosaic" approach to circumstantial evidence)
- Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (flexible similarly-situated inquiry; avoid rigid comparators)
- St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (U.S. 1993) (employer dishonesty can support an inference of discrimination)
- Perez v. Thorntons, Inc., 731 F.3d 699 (7th Cir. 2013) (analysis of stray remarks and inference of discriminatory intent)