Longoria v. Autoneum North America Inc., 3:14-cv-02648

Background

Plaintiff Albert Longoria, a Hispanic Production Supervisor at Autoneum North America, saw an ethnically offensive cartoon on a shared work computer in late 2012, complained to his supervisor (Mackie) and HR, and alleged subsequent threats by Mackie.
Autoneum documented multiple performance problems: failure to issue timely attendance warnings and new-hire evaluations, improper overtime assignments, inaccurate production reports, a public argument with a coworker, and safety/housekeeping lapses.
Autoneum issued a Letter of Concern (Sept. 2012), gave a negative 2012 performance review, placed Longoria on a 90‑day Performance Improvement Plan (PIP) in March 2013, and suspended him after safety-related complaints in April 2013.
Autoneum terminated Longoria on April 12, 2013, citing post-transfer quality, staffing, and safety issues; his duties were reassigned and a non‑Hispanic employee assumed his former duties about 75 days later.
Longoria sued under Title VII and Ohio law for racial and perceived-national‑origin discrimination and for retaliation based on his complaints about the computer-screen incident; defendants moved for summary judgment.
The court granted summary judgment to defendants, holding Longoria failed to make a prima facie discrimination case (replacement timing undermined the claim) and that Autoneum had legitimate, non‑discriminatory reasons for termination which were not shown to be pretextual; the perceived‑national‑origin theory and claims against the parent corporation also failed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race discrimination (Title VII / Ohio) — prima facie elements	Longoria: he is Hispanic, was fired, was qualified, and ultimately replaced by a non‑Hispanic (Shawn Durbin).	Autoneum: Longoria was not replaced promptly; duties were redistributed and the eventual reassignment occurred 75 days later, undermining replacement element.	Court: No prima facie case based on replacement timing; summary judgment for defendant.
Race discrimination — pretext	Longoria: employer's performance reasons were pretext for discrimination tied to his complaints.	Autoneum: documented, ongoing performance problems, warnings, PIP, suspensions provide legitimate reasons.	Court: Employer had honest, reasonable belief in non‑discriminatory reasons; Longoria failed to show pretext.
Perceived‑national‑origin discrimination (Ohio law)	Longoria: Autoneum perceived him as Mexican and fired him for that perceived origin.	Autoneum: Longoria is U.S.‑born; perceived‑origin theory is not a recognized Ohio claim and lacks evidence.	Court: Claim rejected as a legal theory and for failing pretext prong; summary judgment for defendant.
Retaliation (federal and state)	Longoria: he engaged in protected activity (complained about the cartoon); adverse actions followed (suspension, discharge); causal link exists.	Autoneum: legitimate non‑retaliatory reasons for discipline and termination; reasons not pretextual.	Court: Even assuming prima facie case, Longoria failed to show pretext; summary judgment for defendant.

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden‑shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for genuine issue of material fact)
Eastman Kodak Co. v. Image Tech. Servs., Inc., 504 U.S. 451 (summary judgment evidence construed for non‑movant)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for circumstantial discrimination cases)
Wexler v. White's Fine Furniture, Inc., 317 F.3d 564 (qualifications inquiry in prima facie case)
Loyd v. Saint Joseph Mercy Oakland, 766 F.3d 580 (employer investigation and honest‑belief rule)
Grosjean v. First Energy Corp., 349 F.3d 332 (when reassignment constitutes "replacement")
Lilley v. BTM Corp., 958 F.2d 746 (spreading duties among existing employees is not replacement)
St. Jude Med. S.C. v. [named party], [citation="504 F. App'x 473"] (honest‑belief rule; single non‑pretextual reason supports summary judgment)