Schuler v. Ohio Civ. Rights Comm.
2017 Ohio 2602
| Ohio Ct. App. | 2017Background
- In 2001 Paul Schuler filed an Ohio Civil Rights Commission (OCRC) charge alleging reverse discrimination by his employer (GM/Delphi Packard) because white males were subject to a random draw for apprenticeship testing while women and minorities could bypass the draw.
- The OCRC found "Not Probable" in 2002 and dismissed the charge after noting prior litigation and administrative findings that the GM apprenticeship program was lawful and that most selected applicants were white males.
- Schuler sought reconsideration; the OCRC reaffirmed dismissal. He then appealed to the Trumbull County Common Pleas Court under R.C. 4112.06; the trial court affirmed the OCRC in 2016.
- Schuler argued the OCRC and trial court erred by relying on prior federal decisions and by failing to apply Weber and Johnson standards (i.e., showing a manifest imbalance/underrepresentation) required for validating a voluntary affirmative-action plan.
- The appellate court reviewed whether the OCRC’s no-probable-cause finding was unlawful, irrational, or arbitrary and whether prior federal/state rulings addressing the same GM program could be considered.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether OCRC’s "Not Probable" finding was unlawful/irrational/arbitrary | Schuler: OCRC relied on prior federal rulings and failed to independently apply Weber/Johnson; did not show manifest imbalance | OCRC: Program has been repeatedly found non-discriminatory; no record evidence this case differed | Held: No abuse of discretion; OCRC’s decision was reasonable |
| Whether prior federal/state decisions about the same GM program were improperly relied on | Schuler: Those decisions did not properly apply Weber/Johnson and thus are inapplicable | OCRC/GM: Decisions directly address substantially similar program and support non-discrimination finding | Held: Considering those precedents was lawful and reasonable |
| Whether Schuler made a prima facie reverse-discrimination case requiring Weber/Johnson analysis | Schuler: Must show underrepresentation/manifest imbalance relative to labor market | OCRC: Schuler failed to make a prima facie showing; Weber/Johnson framework provides a generic standard but facts lacking | Held: Plaintiff failed to make prima facie case; no need to apply Weber/Johnson in detail |
| Whether trial court erred by not discussing Weber/Johnson explicitly | Schuler: Trial court should have analyzed those cases expressly | OCRC/trial court: So long as conclusion is fundamentally reasonable under proper law, explicit recitation not required | Held: No error—affirmance proper without detailed Weber/Johnson analysis |
Key Cases Cited
- Yeager v. Ohio Civ. Rights Comm., 148 Ohio App.3d 459 (Ohio Ct. App.) (standard for common pleas review of OCRC no-probable-cause finding)
- Coleman v. Warner, 82 Ohio App.3d 263 (Ohio Ct. App.) (same standard articulated)
- United Steelworkers of Am. v. Weber, 443 U.S. 193 (U.S.) (factors for evaluating voluntary affirmative-action plans)
- Johnson v. Transp. Agency, 480 U.S. 616 (U.S.) (prima facie framework and burden-shifting in reverse-discrimination claims)
- Yeager v. Gen. Motors Corp., 265 F.3d 389 (6th Cir.) (upholding GM apprentice program as not discriminatory)
- Garnet v. Gen. Motors Corp., 114 F. Supp. 2d 649 (N.D. Ohio) (rejecting reverse-discrimination claim against GM program)