Meyers v. Goodrich Corp.
2011 Ohio 3261
Ohio Ct. App.2011Background
- Meyers was an at-will production supervisor at Goodrich, terminated in January 2008 after involvement in an internal discrimination investigation.
- Meyers initially sued for age discrimination in March 2008, later amending to add retaliation (and dropping age claim).
- Goodrich moved for summary judgment on retaliation and age claims; trial court granted on retaliation, denied on age claim.
- To establish retaliation under R.C. 4112.02(I), Meyers needed prima facie proof of protected activity, knowledge by decision-makers, adverse action, and causal link.
- Meyers participated in an internal discrimination investigation in January 2007; three decision-makers (Stringer, Rohlfs, Buchanan) were involved in Meyers’ termination.
- The court held Meyers failed to show a causal link or cognizable protected activity, affording summary judgment for Goodrich.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie retaliation requirements | Meyers engaged in protected activity and the decision-makers knew. | No protected activity or knowledge established; no causal link. | Appellate court affirmed summary judgment; no prima facie case shown. |
| Knowledge of protected activity by decision-makers | Buchanan knew Meyers participated; knowledge could be inferred. | Direct evidence of knowledge lacking; limited awareness among decision-makers. | There is a genuine issue of material fact whether Buchanan knew Meyers participated. |
| Temporal proximity and causation | A year between protected activity and termination supports causation. | Temporal proximity alone does not prove causation; need additional evidence. | No causal link established; no evidence of retaliatory conduct between January 2007 and January 2008. |
Key Cases Cited
- Wille v. Hunkar Laboratories, Inc., 132 Ohio App.3d 92 (1998) (prima facie retaliation framework in Ohio cases)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination cases)
- Burdine, 450 U.S. 248 (1981) (pretext framework for retaliation/discrimination)
- Crawford v. Metro. Gov. of Nashville & Davidson Cty., Tenn., 555 U.S. 271 (2009) (opposition to discrimination defined; employee communications can constitute opposition)
- Nguyen v. Cleveland, 229 F.3d 559 (6th Cir. 2000) (causation through proximity and accompanying evidence can survive summary judgment)
- Parries v. Makino, Inc., 148 F. App'x 291 (2005) (retaliation evidence can be demonstrated by ongoing adverse treatment after protected activity)
- Hall v. Banc One Mgt. Corp., 2006-Ohio-913 (Ohio 10th Dist. 2006) (temporal gap between protected activity and adverse action affects causation inference)
- Mickey v. Zeidler Tool & Die Co., 516 F.3d 516 (6th Cir. 2008) (temporal relationship and necessity of additional evidence for causation)
- Clark Cty. Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (close temporal proximity can support causation in some contexts)