Radentz v. Marion County
2011 U.S. App. LEXIS 6817
7th Cir.2011Background
- Nov 2004: Ackles, African-American, elected Marion County Coroner; IU contract subsidizing coroner's office ends 12/31/2004 but IU continues services; 2005: IU stops paying and terminates contract (60 days' notice in July 2005).
- Linehan (then Chief Deputy) identifies need to replace autopsy services; Radentz and Catellier form Forensic Pathology Associates of Indiana and contract with the Coroner's Office is negotiated in Sept 2005 (5 years).
- Contract allows outside autopsies for other counties; supplies for such autopsies provided by the Coroner's Office; cost structure favors IU under prior arrangement; Forensic Pathology contract more costly for Marion County.
- Ackles/Ballew express concern about costs of supplies for outside autopsies; contract termination without cause after six months is invoked; no reason given at termination.
- Plaintiffs contend termination was pretextual and race-based; defendants argue cost concerns are legitimate nondiscriminatory reason; district court granted summary judgment to defendants; Seventh Circuit reverses and remands.
- District court’s decision is reviewed for disputed facts; evidence suggests decision to terminate was not honestly cost-driven and may reflect racial change in office personnel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the contract termination discriminatory against Radentz and Catellier? | Radentz/Catellier claim termination was race-based. | Ackles/Ballew assert cost concerns justified termination. | No summary judgment; triable issue of fact on discriminatory motive. |
| Does McDonnell Douglas framework apply to §1983 equal protection claims here? | Plaintiffs can prove discrimination via indirect method. | Standard applies; defendant must show legitimate nondiscriminatory reason. | Applied; prima facie case shown; burden shifts to defendant to show nondiscriminatory reason. |
| Was the stated cost concern the true reason for termination or pretext? | Costs weren’t the real reason; other evidence indicates race motive. | Costs were the legitimate basis; six-month notice allowed under contract. | There is a factual dispute; pretext possible; remand for trial. |
| Does evidence of statements about replacing white workers with African-Americans support discrimination claim? | Ackles’ and staff remarks show discriminatory intent. | Stray or pre-contract comments not dispositive to termination decision. | Provides support for discrimination; jury could infer intent; issue for trial. |
Key Cases Cited
- Casna v. City of Loves Park, 574 F.3d 420 (7th Cir.2009) (standards for summary judgment and evidence review in discrimination cases)
- Williams v. Seniff, 342 F.3d 774 (7th Cir.2003) (parallel standards for proving intentional discrimination in Title VII and §1983 cases)
- Davis v. Wisconsin Dept. of Corrections, 445 F.3d 971 (7th Cir.2006) (pretext framework for evaluating employer’s nondiscriminatory reasons)
- Davis v. Con-Way Transp. Cent. Express, Inc., 368 F.3d 776 (7th Cir.2004) (pretext analysis and employer’s motivation)
- Argyropoulos v. City of Alton, 539 F.3d 724 (7th Cir.2008) (reliance on business judgment; not always dispositive on motive)
- Culver v. Gorman & Co., 416 F.3d 540 (7th Cir.2005) (pretext and evaluation of evidence supporting discriminatory action)
- Adelman-Reyes v. Saint Xavier University, 500 F.3d 662 (7th Cir.2007) (overlap of prima facie and pretext analyses; sequential burden shifting)