YODHES v. ONEAMERICA FINANCIAL PARTNERS, INC.
1:16-cv-02803
| S.D. Ind. | Apr 16, 2018Background
- Betty Yodhes was hired by American United Life Insurance Company (AUL) in Sept. 2014 as a Plan Manager; within weeks she was assigned a heavy caseload including a client (MNS) transferred from another manager.
- Yodhes alleges supervisor Joe Miller stared at her chest repeatedly, berated her in an angry Feb. 2–3, 2015 meeting, and engaged in intimidating conduct; she also received multiple client complaints about her performance.
- Yodhes disclosed uterine fibroids and requested intermittent work-from-home accommodations for medical appointments and pain; she took approved leave for surgery in March 2015 and did not return, resigning effective March 30, 2015.
- Yodhes filed EEOC charges (disability in March 2015; sex in September 2015) and sued asserting sex discrimination, hostile work environment, disability discrimination (including failure to accommodate), and retaliation; AUL counterclaimed for unpaid relocation reimbursement under a signed agreement.
- The district court considered AUL’s summary judgment motion and applied the sham-affidavit rule where appropriate, ultimately granting summary judgment to AUL on all claims and finding AUL entitled to recover relocation expenses and costs under the agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller's conduct created a sexually hostile work environment under Title VII | Miller repeatedly stared at Yodhes' breasts and directed hostile conduct at women, creating an objectively and subjectively hostile environment | Conduct was rude but not sufficiently severe or pervasive to alter employment terms | Court: No hostile environment; conduct insufficiently severe or pervasive |
| Whether Yodhes was constructively discharged (sex discrimination/disparate treatment) | Working conditions were intolerable after harassment and client criticisms, forcing her to resign | Yodhes voluntarily quit after leave; conditions not so intolerable; no showing of males treated more favorably | Court: No constructive discharge; no prima facie disparate treatment shown |
| Whether AUL retaliated against Yodhes for complaining about Miller or filing EEOC charge | Complaints to HR and EEOC were protected activity and employer actions were retaliatory leading to her exit | No causal link shown; Yodhes did not identify similarly situated employees treated better | Court: Retaliation claim fails; no prima facie causal or comparative evidence |
| Whether AUL violated the ADA (failure to accommodate / disparate treatment / retaliation) | Yodhes informed supervisor of medical condition and requested work-from-home when symptomatic; request denied | Plaintiff offered insufficient evidence tying adverse actions to disability or showing required elements of ADA claims | Court: ADA claims forfeited by undeveloped briefing and lack of evidentiary support; summary judgment for AUL |
| Whether AUL is entitled to recover relocation payments under contract | Yodhes contends her resignation was constructive so repayment not triggered | Agreement required 100% repayment if employment ended within 12 months; Yodhes did not repay | Court: AUL entitled to summary judgment on counterclaim; Yodhes liable for relocation reimbursement and costs |
Key Cases Cited
- Zerante v. DeLuca, 555 F.3d 582 (7th Cir.) (summary-judgment evidence viewed in light most favorable to nonmovant)
- Buckner v. Sam’s Club, Inc., 75 F.3d 290 (7th Cir.) (sham-affidavit rule prevents contradicting prior sworn testimony)
- Russell v. Acme-Evans Co., 51 F.3d 64 (7th Cir.) (affidavit contradictions disregarded unless reasonable explanation exists)
- Vance v. Ball State Univ., 133 S. Ct. 2434 (U.S.) (hostile work environment standard and employer liability principles)
- Liu v. Cook Cty., 817 F.3d 307 (7th Cir.) (elements for hostile work environment claim)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S.) (burden-shifting framework for disparate-treatment claims)
- Hooper v. Proctor Health Care Inc., 804 F.3d 846 (7th Cir.) (application of McDonnell Douglas and proof requirements)
- Roby v. CWI, Inc., 579 F.3d 779 (7th Cir.) (constructive discharge requires more egregious conditions than hostile work environment)
- Racicot v. Wal-Mart Stores, 414 F.3d 675 (7th Cir.) (isolated or rude conduct falls short of actionable harassment)
- Corley v. Rosewood Care Ctr., Inc. of Peoria, 388 F.3d 990 (7th Cir.) (court need not scour record or build arguments for a party)