A former Indianapolis lab technician presented enough evidence to support her claims of discrimination and retaliation that the 7th Circuit Court of Appeals overturned summary judgment in favor of her former employer.
Chontel Miller filed a lawsuit against Polaris Laboratories after she was fired for not meeting performance goals. She was required to process 260 samples daily and over eight months, she never hit that level of productivity.
Miller, who was the only African-American processing technician, claimed racial discrimination caused her work to suffer. She charged her supervisors made racially derogatory comments about her and manipulated her trays of samples so she had more difficult work to do which slowed her down.
The U.S. District Court for the Southern District of Indiana granted Polaris’ motion to dismiss. Initially, the District Court denied summary judgment to Polaris on the discrimination claim, finding Miller had presented sufficient evidence under a cat’s paw theory that the racial bias of supervisors led to management’s decision to terminate her employment.
On reconsideration, the District Court agreed with Polaris that Miller had no evidence supporting her claim that the manipulation of her work by her supervisors could systematically reduce her productivity.
The 7th Circuit Court of Appeals did not agree. It found Miller had demonstrated a dispute of material fact on both her claims and reversed the ruling in Chontel M. Miller v. Polaris Laboratories, LLC, 14-2621.
Polaris countered that Miller’s firing was a direct consequence of her poor job performance. Miller did not dispute she was not meeting her quota but she argued her supervisors, acting upon their racial animus, tampered with her work.
The Chicago panel concluded Miller had cleared the hurdle by showing a dispute of fact on the question of whether the actions of the middle managers were motivated by racial animus. She presented evidence the supervisors referred to her in racially inappropriate terms.
On the more difficult question of whether her supervisors purposefully sabotaged her work and caused her termination, the 7th Circuit found Miller was also successful. In particular, the judges noted, Miller does not have to prove systematic tampering at this point. Rather, she only needs to produce evidence that raises an inference that such tampering occurred to the extent it slowed her productivity.
“It may be difficult to marshal evidence that coworkers and lower-level supervisors harbored discriminatory animus against a plaintiff and thwarted her ability to perform her work effectively, and it may be even harder to show that this is what lies behind a decisionmaker’s adverse job action,” Chief Judge Diane Wood wrote for the court. “Taking the summary judgment record in the light most favorable to Miller, however, as we must, we conclude that she has made it over the line. Although Polaris has some evidence that Miller’s work could not have been manipulated to the extent she claims, it is not ironclad.”