Myron Mintz v. Caterpillar Inc.
788 F.3d 673
| 7th Cir. | 2015Background
- Myron Mintz, an African American manufacturing engineer at Caterpillar, alleged race discrimination and retaliation under Title VII and § 1981 after receiving progressively worse performance ratings in 2011, culminating in a 2011 year-end "4–Needs Improvement" that reduced his bonus.
- Key performance issues cited by Caterpillar were high levels of "grief" (discrepancies between customer orders and production instructions, including urgent "1410" grief) and numerous past-due engineering change-order folders; these responsibilities were central to the manufacturing engineer role.
- Mintz acknowledged the elevated grief and past-due folders but argued the employer’s expectations (e.g., "zero grief") were unrealistic and that the negative ratings were motivated by race and retaliation following his May 2011 complaint to HR.
- Caterpillar moved for summary judgment after discovery; Mintz missed the response deadline, the district court granted summary judgment for Caterpillar, and then denied Mintz’s motions to vacate or to file a late response (which the court erroneously treated as a Rule 60(b) motion but nevertheless reviewed the belated submission).
- The Seventh Circuit affirmed: it found Mintz failed to make out a prima facie discrimination case (not meeting legitimate expectations; no evidence of more-favorable treatment of similarly situated non-protected employees) and failed to show causation for retaliation given the lack of corroborating evidence and the temporal gap.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural: Proper standard for post-judgment motions / late filing | Mintz argued he mistakenly failed to timely file and sought relief and leave to file a late summary-judgment response | Caterpillar maintained summary judgment was proper; district court treated filings as Rule 60(b) and denied relief | Court held district court erred to treat the motions as Rule 60(b) (since no final judgment yet) but the error was harmless because the court reviewed the belated submission and outcome would not change; affirmed judgment for Caterpillar |
| Discrimination prima facie: whether Mintz met employer’s legitimate expectations | Mintz argued his overall contributions and successes showed he met expectations; employer’s goals were unrealistic | Caterpillar showed high grief/past-due change orders established he was not meeting expectations | Held Mintz failed to show he met legitimate expectations (grief and past-due folders were materially deficient) |
| Discrimination prima facie: similarly situated comparators | Mintz claimed disparate treatment but identified no nonprotected employees treated better for comparable conduct | Caterpillar argued no comparator evidence exists | Held Mintz produced no evidence of similarly situated employees who were treated more favorably; independent failure of prima facie case |
| Retaliation: causation between complaint and adverse action | Mintz asserted his May 2011 complaint led to the adverse 2011 year-end evaluation (Feb 2012) | Caterpillar argued distant timing and lack of corroborating evidence defeat causal inference; poor performance explains evaluation | Held timing (≈9 months) and lack of corroborating evidence are insufficient to infer causation; retaliation claim fails (also fails under indirect method because he did not meet expectations) |
Key Cases Cited
- Huang v. Cont’l Cas. Co., 754 F.3d 447 (7th Cir.) (standard of review for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct.) (summary judgment framework)
- Smiley v. Columbia Coll. Chi., 714 F.3d 998 (7th Cir.) (Title VII and § 1981 standards treated alike)
- Simpson v. Beaver Dam Cmty. Hosps., Inc., 780 F.3d 784 (7th Cir.) (direct and indirect methods for discrimination)
- Moultrie v. Penn Aluminum Int’l, LLC, 766 F.3d 747 (7th Cir.) (elements of indirect method; retaliation framework)
- Sklyarsky v. Means-Knaus Partners, L.P., 777 F.3d 892 (7th Cir.) (temporal proximity alone insufficient for causation)
- Santamarina v. Sears, Roebuck & Co., 466 F.3d 570 (7th Cir.) (Rule 60(b) applies only to final judgments)
- Coleman v. Donahoe, 667 F.3d 835 (7th Cir.) (courts do not act as super-personnel departments)