Peggy Blizzard v. Marion Technical College, 2012 U.S. App. LEXIS 21846

Background

Blizzard, born January 18, 1951, was terminated in April 2008 from Marion Technical College at age 57.
Replacement was Kristina Teeter (born July 13, 1957); Blizzard’s duties were reassigned while Thomas temporarily assumed Blizzard’s work.
MTC attributed Blizzard’s dismissal to performance failures with the new software, uncooperative conduct, and absences.
Blizzard alleged age discrimination and retaliation, asserting Nutter treated her differently than younger employees.
Blizzard filed an EEOC charge in June 2008 and a federal complaint in July 2009; district court granted summary judgment for defendants.
On appeal, the Sixth Circuit reviews the district court’s summary judgment de novo and analyzes ADEA claims under McDonnell Douglas with an honest-belief pretext framework.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie ADEA claim viability given replacement age gap	Blizzard asserts Teeter’s six-and-a-half year younger age shows discrimination	Grosjean rule treats 6–10 year gaps as case‑specific; Teeter’s age difference is not automatically significant	Material-fact issue exists; district court’s view reasonable under Grosjean
Pretext for termination	Proffered reasons lack factual basis; coworker opinions and later evidence show pretext	Employer’s relied-upon facts were reasonable and supported by performance evaluations and memos	No pretext; employer’s honest-belief standard upheld; summary judgment affirmed
Retaliation claim viability	Protected activities (2006–2007 complaints) caused termination	Causation failure; timing insufficient; some complaints not clearly protected activity	Retaliation claim failed; no causal link established

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes prima facie case and pretext framework)
Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (U.S. 2009) (but-for causation in ADEA claims)
Geiger v. Tower Auto., 579 F.3d 614 (6th Cir. 2009) (direct or circumstantial evidence analysis under McDonnell Douglas)
Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (6th Cir. 1998) (use of employer’s memorandum; evidence of legitimate reasons for termination)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (credibility and evidentiary weight in evaluating pretext)
Majewski v. ADP, Inc., 274 F.3d 1106 (6th Cir. 2001) (pretext framework and evidence standard)
Chattman v. Toho Tenax Am., Inc., 686 F.3d 339 (6th Cir. 2012) (three-part pretext test; evidence must show pretext)
Smith v. Chrysler Corp., 155 F.3d 799 (6th Cir. 1998) (honest belief standard; permissible reliance on employer’s internal investigations)
Grosjean v. First Energy Corp., 349 F.3d 332 (6th Cir. 2003) (six-year age-difference rule; 6–10 year band evaluated case-by-case)
Hamilton v. General Electric Co., 556 F.3d 428 (6th Cir. 2009) (pretext evidence where employer’s stated reasons are contested as pretext)
Lindsay v. Yates, 578 F.3d 407 (6th Cir. 2009) (temporal proximity sufficiency depends on closeness in time)
Ladd v. Grand Trunk Western R.R., Inc., 552 F.3d 495 (6th Cir. 2009) (causation in retaliation claims)
Reeves v. Cincinnati Bell Tel. Co., 681 F.3d 274 (6th Cir. 2012) (Hamilton cited Reeves for evidentiary approach)