Schandelmeier-Bartels v. Chicago Park District
634 F.3d 372
| 7th Cir. | 2011Background
- Cathleen Schandelmeier, Caucasian, was employed as Cultural Coordinator by the Chicago Park District (South Shore Cultural Center).
- Her supervisor Andrea Adams, African-American, harbored racial animus revealed in a tirade against Schandelmeier.
- Schandelmeier reported witnessing what she believed was child abuse by J.J.'s African-American aunt; she was terminated within hours.
- Adams drafted racist/biased internal memos; a memo attributed to Adams described Schandelmeier as lacking order over camp.
- J.J. incident and related memos contributed to the termination decision, which was executed August 1, 2006.
- District court granted judgment as a matter of law for Park District; on appeal, the Seventh Circuit reinstated liability for Schandelmeier and remanded for damages reduction to $30,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether bias by a non-decisionmaker can taint the employment decision. | Schandelmeier argues Adams’s racial bias infected the termination. | Park District contends bias was notSingular influence; independent investigation broke chain. | Yes; bias could be singular influence supporting liability. |
| Who was the actual decisionmaker and did Adams have decisive influence. | Adams’s bias influenced the ultimate termination decision. | McDonald or Rowland made the formal decision; Adams’s influence uncertain. | Evidence supported Adams’s decisive influence over termination; reversible error to grant JMOL. |
| Was there an independent investigation that severed the cat's paw causal chain. | Park District failed to conduct independent investigation. | Investigation could be independent. | Insufficient independence; jury could find Adams’s input tainted the decision. |
| Whether the compensatory damages award of $200,000 was reasonable. | Award properly reflects emotional distress and disruption. | Award excessive given evidence of only limited harm and isolated incidents. | Remand to reduce to $30,000; the higher award was not supported by the record. |
Key Cases Cited
- Martino v. MCI Communications Services, Inc., 574 F.3d 447 (7th Cir. 2009) (biased non-decisionmaker influence required for liability; singular influence considered)
- Staub v. Proctor Hosp., 560 F.3d 647 (7th Cir. 2009) (employer liable when biased non-decisionmaker exerts influence over decisionmaker)
- Lust v. Sealy, 383 F.3d 580 (7th Cir. 2004) (cat's paw theory can apply with non-decisionmaker's bias contributing to decision)
- Willis v. Marion County Auditor's Office, 118 F.3d 542 (7th Cir. 1997) (affirmed judgment for employer where bias did not influence decisionmaking)
- Shager v. Upjohn Co., 913 F.2d 398 (7th Cir. 1990) (conduit/tainted information to decisionmaker can implicate employer)
- Marion County Coroner's Office v. Equal Employment Opportunity Comm'n, 612 F.3d 924 (7th Cir. 2010) (emotional damages framework and district court deference in awards)