Stephanie Carlson v. CSX Transportation, Incorpora
758 F.3d 819
| 7th Cir. | 2014Background
- Stephanie Carlson, a CSX employee, sued under Title VII for sex discrimination and retaliation and asserted a related breach of a no-retaliation settlement clause after a 2007 discrimination suit she later settled in 2009.
- While in CSX’s manager‑training program (and during settlement negotiations), Carlson alleges supervisors belittled her, assigned extra work, and gave unfair evaluations causing her to withdraw (constructive demotion theory).
- After leaving training she was denied reinstatement as a substitute yardmaster in Birmingham and later was rejected for multiple substitute yardmaster openings; Carlson alleges men were treated differently and CSX gave inconsistent reasons for denials.
- The district court dismissed most claims under Rule 12(b)(6) for failing to plead plausibly and held two surviving claims precluded by the Railway Labor Act (RLA) as grounded in the collective bargaining agreement; it also dismissed Carlson’s contract claim for failure to produce the settlement agreement (though Carlson had submitted it under seal).
- On appeal the Seventh Circuit reversed: it held Carlson’s Title VII discrimination and retaliation claims and her contract claim survived pleading-stage review, and the RLA did not preclude her statutory and contract claims from court adjudication.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Title VII discrimination pleadings | Carlson pleaded which jobs she sought, denials, and alleged sex‑based motive; that is enough at pleading stage. | CSX argued many claims lacked comparator or other details making them implausible. | Reversed: Title VII discrimination claims pleaded plausibly under Swierkiewicz/Tamayo standards. |
| Sufficiency of Title VII retaliation pleadings (including alleged ongoing pattern) | Carlson alleged protected activity (EEOC charges, 2007 suit) and an ongoing pattern of retaliatory adverse actions. | CSX argued timing gaps (months) made causation implausible. | Reversed: timing not dispositive where complaint alleges ongoing campaign; retaliation claims plausible. |
| Constructive demotion/constructive discharge theory for training program treatment | Carlson alleges intolerable treatment that forced her out of training (constructive demotion). | CSX (and district court) said allegations were conclusory and lacked overt discriminatory statements/evidence. | Reversed: factual allegations adequate at pleading stage to state constructive demotion/discrimination and retaliation claims. |
| RLA preclusion / mandatory arbitration | Carlson: her claims arise under Title VII and a private settlement contract, not under the CBA, so RLA arbitration does not bar federal suit. | CSX: refusal to reinstate was justified by the CBA, so claims are "grounded in" the CBA and must go to arbitration. | Reversed: RLA does not preclude Title VII and contract claims that raise independent rights and require factual inquiry into discriminatory/retaliatory motive rather than interpretation of the CBA. |
Key Cases Cited
- Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308 (pleading standards on Rule 12(b)(6) review)
- Tamayo v. Blagojevich, 526 F.3d 1074 (7th Cir.) (construe complaint in plaintiff’s favor)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (Title VII claims need only short, plain statement; no heightened pleading)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading plausibility standard)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Concentra Health Servs., Inc. v. EEOC, 496 F.3d 773 (7th Cir.) (simplicity of Title VII pleading)
- Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (RLA preclusion: independent statutory/state claims may proceed in court)
- Atchison, Topeka & Santa Fe Ry. Co. v. Buell, 480 U.S. 557 (RLA arbitration limits and relation to statutory claims)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (jurisdictional versus claim‑element analysis)
- Becker v. Montgomery, 532 U.S. 757 (curable filing defects and effect on appeal timing)
- University of Texas Southwestern Medical Center v. Nassar, 570 U.S. 338 (retaliation requires but‑for causation)