Rhonda Finley v. City of Trotwood, 503 F. App'x 449

Finley, an African-American woman, started at Trotwood in 1997 and was promoted in 2006 to Director of Planning and Development with a 21.27% pay raise.
Lucking, the City Manager, implemented budget cuts including vehicle-sharing and a reclassification that reduced a white male director’s salary, affecting Finley’s department indirectly.
A budget committee proposed eliminating the Planning Director role and creating an Economic Development Administrator, with Lucking absorbing residual duties.
Finley’s salary was reduced in 2009, she lost supervisory duties and a chamber-board role, and a 7.5% pay reduction for non-union employees was applied mid-2009.
Finley filed EEOC charges in late 2008 alleging discrimination and retaliation, later adding age discrimination; she claimed adverse actions followed these charges.
The district court granted summary judgment to Trotwood and Lucking; Finley appealed, with the court affirming on all federal and state claims and the IIED claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Finley proved race, gender, or age discrimination.	Finley contends she was treated less favorably than comparators and replaced.	Finley was not replaced; pay disparities and duties were consistent with budget-driven changes and with non-protected comparators.	No material triable issue; no discrimination shown.
Whether Finley established retaliation and hostile work environment.	Retaliation followed EEOC filing; actions like exclusion from meetings and adverse memoranda were punitive.	The actions were not materially adverse; no severe/pervasive harassment shown.	Summary judgment affirmed for retaliation and hostile environment.
Whether Finley’s wage-discrimination claim under EPA/Ledbetter/ADEA is timely and proven.	Wage discrimination occurred due to disparate pay for protected classes in comparable roles.	Salary differences aligned with duties; no prima facie wage discrimination shown.	No prima facie wage discrimination; timeliness rejected for the first period.
Whether state-law claims against Lucking and Trotwood fail.	State claims mirror federal claims and should proceed.	State and federal analyses align; reliance on federal law controls; no viable state claims.	State claims affirmed as meritless.
Whether Finley’s intentional infliction of emotional distress claim survives.	Actions were extreme and outrageous.	No evidence of extreme and outrageous conduct.	IVD claim rejected; summary judgment affirmed.

Hartsel v. Keys, 87 F.3d 795 (6th Cir. 1996) (discrimination summary-judgment standard; burden-shifting framework)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden shifting; movant need show absence of evidence)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (prima facie case framework for discrimination)
Griffin v. Finkbeiner, 689 F.3d 584 (6th Cir. 2012) (McDonnell Douglas framework application in discrimination)
Schoonmaker v. Spartan Graphics Leasing LLC, 595 F.3d 261 (6th Cir. 2010) (downsizing not replacement; duties redistributed)
Russell v. Univ. of Toledo, 537 F.3d 596 (6th Cir. 2008) (causation in retaliation claims; adverse action threshold)
Randolph v. Ohio Dep’t of Youth Servs., 453 F.3d 724 (6th Cir. 2006) (hostile-work-environment standard; severity and pervasiveness)
Plumbers & Steamfitters Joint Apprenticeship Comm. v. Ohio Civil Rights Comm’n, 421 N.E.2d 128 (Ohio 1981) (state discrimination standard; parallel to federal framework)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (materially adverse action defined for retaliation)
Ortiz v. City of Chicago, n/a (n/a) (not included in official reporter list; placeholder not used)