Romans v. Michigan Department of Human Services, 668 F.3d 826

Plaintiff Romans, a Caucasian male, alleges Title VII race discrimination by Michigan DHS and FMLA interference/retaliation.
Romans worked as a Fire and Safety Officer at Maxey Training School since 2000; CC1 monitors cameras and access, CC2 is back-up; postings require relief before leaving CC1.
Union contract limited disciplinary actions; formal/informal counseling not considered disciplinary, and disciplinary records can be removed after 12 months absent similar conduct.
A prior history includes suspensions and formal counselings from 2005–2008 for various conduct; Perteet harassment complaints and ensuing investigations were central to the case.
Hall-Thiam investigated Perteet’s harassment claims against Romans; the Office of Labor Relations conducted a second investigation; Romans was ultimately terminated in 2008.
District court granted summary judgment for DHS on Title VII; Romans appealed seeking reversal for FMLA claims, which the Sixth Circuit partially granted, vacating and remanding on FMLA issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Romans’ Title VII claim was proven direct or circumstantial.	Hall-Thiam report shows racial animus; Dean as conduit—cat’s paw theory; or sufficient circumstantial evidence under McDonnell Douglas.	Hall-Thiam’s bias cannot be imputed to final decisionmaker; independent investigation breaks causal link; no pretext shown.	No direct or circumstantial evidence supports discrimination; Title VII claim fails.
Whether DHS interfered with Romans’ FMLA rights.	Regulations permit leave to care for a family member and to make arrangements for changes in care; denial was not justified.	Facility coverage requirements and need to fill shifts; denial was justified by operational needs.	Material factual dispute exists; FMLA interference claim survives summary judgment.
Whether Romans’ FMLA retaliation claim is viable.	Suspension for leaving to care for his mother was retaliation for exercising FMLA rights; linked to termination.	Discipline based on leave was for legitimate non-discriminatory reasons; pretext not shown.	Romains’ FMLA retaliation claim survives summary judgment.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes framework for proving circumstantial discrimination)
Staub v. Proctor Hosp., 131 S. Ct. 1901 (Supreme Court 2011) (independent investigation can sever cat's paw causation when justified)
Grace v. USCAR & Bartec Tech. Servs., 521 F.3d 655 (6th Cir. 2008) (interference claims require showing permissible denial of FMLA rights)
Wright v. Murray Guard, Inc., 455 F.3d 702 (6th Cir. 2006) (reasonableness of employer’s reliance on particularized facts in termination decisions)
Chen v. Dow Chemical Co., 580 F.3d 394 (6th Cir. 2009) (pretext framework for evaluating discrimination in reverse-prong cases)
Madden v. Chattanooga City Wide Serv. Dep’t, 549 F.3d 666 (6th Cir. 2008) (cat's paw and causal nexus considerations in discrimination claims)
Zambetti v. Cuyahoga Cmty. Coll., 314 F.3d 249 (6th Cir. 2002) (background circumstances can support reverse-discrimination claims)