Shazor v. Professional Transit Management, Ltd.
744 F.3d 948
6th Cir.2014Background
- Plaintiff Marilyn Shazor was SORTA’s CEO (and PTM’s liaison) from March 2008, under an at-will contract with PTM; PTM provided SORTA with management services.
- Tensions rose as PTM officials questioned her loyalty and she resisted PTM education programs; internal emails disparaged her as a “prima donna” and criticized her leadership and accessibility.
- In 2009–2010, SORTA contracted with MPI to advise on labor relations; disputes arose over MPI’s retention and who controlled labor strategy, including unionization efforts.
- Shazor testified she did not participate in selecting MPI; Board discussions in July–August 2010 raised concerns about her honesty and competence relating to labor relations decisions.
- On August 13, 2010, Hock fired Shazor; Crews, an Hispanic woman, was selected as permanent replacement in November 2010.
- The district court granted summary judgment to PTM and Hock on discrimination claims; the Sixth Circuit reversed and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether direct evidence suffices to sustain a Title VII claim without McDonnell Douglas. | Shazor asserts direct evidence of discrimination. | Defendants argue cat’s-paw and reliance on indirect proof. | Issue reserved for trial; direct-evidence question not resolved on summary judgment. |
| Whether Shazor established circumstantial evidence of race and sex discrimination via a prima facie case and pretext. | Shazor shows replacement by non-protected class and pretext through lies alleged by Hock. | Defendants contend proffered reasons are legitimate and non-discriminatory. | Plaintiff set a prima facie case and raised genuine issues about pretext; summary judgment reversed. |
| Whether the evidence supports cat’s-paw liability for Setzer/Scott’s statements. | Emails show racial/sex-based hostility influencing the decision. | Liability requires supervisors’ bias to be proximate cause; unclear if Setzer/Scott qualify as supervisors. | Question unresolved on summary judgment; remand to resolve supervisor status and causation. |
| Whether the honest-belief doctrine shields Defendants from liability. | Even if lies occurred, investigation lacked particularized facts. | Hock reasonably relied on a limited investigation anchoring the termination. | Honest-belief doctrine does not apply; genuine factual issues remain. |
Key Cases Cited
- Staub v. Proctor Hosp., 131 S. Ct. 1901 (2011) (cat’s-paw liability requires proximate cause by supervisor’s bias)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (familiar framework for circumstantial discrimination proof)
- Griffin v. Finkbeiner, 689 F.3d 584 (6th Cir. 2012) (prima facie standard and shifting burdens in retaliation cases)
- Talley v. Bravo Pitino Rest., Ltd., 61 F.3d 1241 (6th Cir. 1995) (sex-plus discrimination framework; evidentiary standards)