Ronald Sweatt v. Union Pacific Railroad Co
796 F.3d 701
| 7th Cir. | 2015Background
- Sweatt, an African-American Union Pacific employee (2006–2011), suffered shoulder and hand pain from manual labor duties.
- He sought a less strenuous Security Officer role through UP's Vocational Rehabilitation Program but was not hired.
- Sweatt alleged FELA injuries (physical harms) and age/race discrimination under ADAA and ADEA for the denial of the Security Officer position.
- Key dates: pain noticed May–June 2009; hand pain noted November 2009; Dr. Coates opined Sweatt unfit for Trackman on November 30, 2009; Sweatt filed suit November 30, 2012.
- VRP process included interviews and background checks; a LEADS/NCIC arrest report surfaced, showing a past arrest, which Sweatt initially denied during interviews.
- Comparators showed UP hired others; Sweatt argued these comparators reveal discrimination but district court granted summary judgment against him on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FELA accrual barred Sweatt's claims | Sweatt contends accrual occurred after his injury manifested and so within 3-year window. | Union Pacific argues accrual occurred by May/June 2009 (injury manifested) and thus time-barred by 3-year limit. | FELA claims accrued before November 2009 and are time-barred. |
| Whether Sweatt proves prima facie race discrimination | Comparators show a non-level hiring field for Security Officer based on race. | Comparators are not directly comparable in all material respects; defense argues no pretext established. | No prima facie race discrimination; comparators not sufficiently similar. |
| Whether Sweatt proves prima facie age discrimination | ADEA coverage and comparators show discrimination based on age. | Comparators were not similar, and the reason for not hiring was honesty in interview. | No prima facie age discrimination; comparators not sufficiently similar. |
| Whether the district court's CMP for summary judgment complied with rules | CMP restricts non-movants from supplementing facts, violating Local Rule 56.1 and Rule 83. | CMP aligns with Local Rule 56.1 and clarifies undisputed facts; did not prejudice Sweatt. | CMP upheld as consistent with Local Rule 56.1; no error. |
Key Cases Cited
- Fries v. Chicago & Nw. Transp. Co., 909 F.2d 1092 (7th Cir. 1990) (accrual begins when injury and cause are known or knowable)
- Tolston v. Nat’l R.R. Passenger Corp., 102 F.3d 863 (7th Cir. 1996) (actual notice not required for accrual; awareness suffices)
- Green v. CSX Transp., Inc., 414 F.3d 758 (7th Cir. 2005) (injury accrues when injury manifests in repetitive exposure cases)
- Coleman v. Donahoe, 667 F.3d 835 (7th Cir. 2012) (similarly situated requirement for prima facie cases under McDonnell Douglas)
- EEOC v. Target Corp., 460 F.3d 946 (7th Cir. 2006) (pretext requires showing dishonest nondiscriminatory reason)
- Krchnavy v. Limagrain Genetics Corp., 294 F.3d 871 (7th Cir. 2002) (prerequisite elements for prima facie discrimination claims; burden shifting)
- Zaccagnini v. Chas. Levy Circulating Co., 338 F.3d 672 (7th Cir. 2003) (pretext inquiry in discrimination cases)
- Norman-Nunnery v. Madison Area Tech. Coll., 625 F.3d 422 (7th Cir. 2010) (pretext framework for discrimination claims)
- Conrail v. Gottshall, 512 U.S. 532 (1994) (federal remedial framework for railroad employee claims)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard: genuine issues of material fact)