Stanfield v. United States Steel Corp.
2013 Ohio 2378
Ohio Ct. App.2013Background
- Stanfield filed suit against U.S. Steel alleging retaliatory discharge under R.C. 4123.90 and intentional infliction of emotional distress.
- U.S. Steel moved for summary judgment; the trial court granted it.
- The court of appeals reverses the trial court’s grant of summary judgment on retaliation.
- Evidence included Stanfield’s injury at work, medical reports, surveillance video, and alleged statements by supervisors about terminating for filing a workers’ compensation claim.
- The court analyzes a burden-shifting framework for retaliatory-discharge claims and whether the employer’s conduct could be extreme and outrageous for IIED.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case for retaliation established? | Stanfield showed on‑the‑job injury, workers’ comp claim, and causal link to termination. | Evidence failed to prove a prima facie retaliation case. | Yes; genuine issues of material fact remain precluding summary judgment. |
| Extreme and outrageous conduct for IIED claim? | Management conduct and meeting behavior were extreme and outrageous. | Termination actions alone are not enough to prove IIED. | Yes; disputed facts preclude summary judgment on IIED. |
Key Cases Cited
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (Ohio 1977) (summary-judgment standard and burden-shifting framework)
- Dresher v. Burt, 75 Ohio St.3d 280 (Ohio 1996) (initial burden on movant under Civ.R.56(C))
- Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (Ohio 1996) (de novo review of summary judgment)
- White v. Mt. Carmel Med. Ctr., 150 Ohio App.3d 316 (Ohio App. 2002) (retaliation policy and prima facie framework discussion)