Yazdian v. Conmed Endoscopic Technologies, Inc.
793 F.3d 634
| 6th Cir. | 2015Background
- Yazdian, an Iranian‑American, non‑practicing Muslim, worked as a ConMed territory manager from 2005 until his termination on July 26, 2010; he had strong sales performance but a fraught relationship with his supervisor, Tim Sweatt.
- Throughout 2008–2010 Yazdian complained to Sweatt and others about perceived discrimination and a “hostile work environment,” and made statements indicating he would respond with counsel and bring charges.
- Sweatt documented multiple instances he characterized as Yazdian’s ‘‘behavioral issues’’ (combativeness, rudeness, refusal to accept coaching), and ConMed issued a written warning on July 13, 2010.
- ConMed investigated only briefly; Hebbard interviewed Yazdian (disputed content/scope), closed the inquiry, and ConMed terminated Yazdian on July 26, 2010, citing insubordination and misconduct.
- Yazdian filed EEOC charges; after a probable‑cause finding he sued under Title VII alleging retaliation and national‑origin/religion discrimination. The district court granted summary judgment for ConMed; the Sixth Circuit reversed as to retaliation and affirmed as to discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retaliation: whether Yazdian engaged in protected activity and was terminated in retaliation | Yazdian argued his complaints (including calling the workplace a “hostile work environment” and threats to respond with counsel) constituted protected opposition to discrimination and that termination eight weeks later was retaliatory; Sweatt’s reliance on those complaints as insubordination shows retaliatory motive | ConMed argued Yazdian’s complaints were vague or managerial gripes (not protected), and termination was for legitimate nondiscriminatory reasons (insubordination, combativeness), not retaliation | Reversed: a reasonable jury could find Yazdian engaged in protected activity, temporal proximity plus Sweatt’s references to those complaints could show direct/circumstantial evidence of retaliation; summary judgment improper on retaliation claim (remanded) |
| Discrimination (national origin / religion): whether termination was motivated by anti‑Iranian or anti‑Muslim animus | Yazdian pointed to several incidents (Persia article, Honey Baked Ham email, favoritism toward other managers) as evidence of animus and pretext for termination | ConMed maintained those incidents were benign or mischaracterized and offered nondiscriminatory reasons for firing (insubordination, prior behavioral issues) | Affirmed: the incidents were insufficient to show ConMed’s stated reasons were pretext for discrimination; no reasonable jury could find termination was due to national origin or religion |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard and inferences)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination claims)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (but‑for causation standard for Title VII retaliation)
- Imwalle v. Reliance Med. Prods., Inc., 515 F.3d 531 (direct and circumstantial evidence in retaliation claims)
- Johnson v. Univ. of Cincinnati, 215 F.3d 561 (what constitutes protected opposition under Title VII)
- Fox v. Eagle Distrib. Co., 510 F.3d 587 (vague complaints not protected)
- Booker v. Brown & Williamson Tobacco Co., 879 F.2d 1304 (vagueness defeats protected activity claim)
- EEOC v. New Breed Logistics, 783 F.3d 1057 (opposition may include complaints to managers/co‑workers)
- Wright v. Murray Guard, Inc., 455 F.3d 702 (honest‑belief doctrine for employer’s stated reason)