Aaron Minner v. General Motors LLC

CourtMichigan Court of Appeals
DecidedJune 6, 2024
Docket363462
StatusUnpublished

This text of Aaron Minner v. General Motors LLC (Aaron Minner v. General Motors LLC) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aaron Minner v. General Motors LLC, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

AARON MINNER, UNPUBLISHED June 6, 2024 Plaintiff-Appellee,

v No. 363462 Genesee Circuit Court GENERAL MOTORS LLC, LC No. 18-111875-CD

Defendant-Appellant,

and

JEFF LUGGER,

Defendant.

Before: MARKEY, P.J., and RIORDAN and CAMERON, JJ.

PER CURIAM.

In this action under the Elliott Larsen Civil Rights Act (ELCRA), MCL 37.2101 et seq., defendant General Motors LLC appeals by leave granted1 the trial court’s June 9, 2022 opinion and order granting in part and denying in part its motion for summary disposition under MCR 2.116(C)(10). On appeal, defendant argues that the trial court erred by denying its motion for summary disposition with respect to plaintiff Aaron Minner’s ELCRA claims for race discrimination and hostile work environment. We affirm in part, reverse in part, and remand to the trial court for further proceedings.

I. FACTS

1 See Minner v Gen Motors LLC, unpublished order of the Court of Appeals, entered March 23, 2023 (Docket No. 363462).

-1- On November 8, 2018, plaintiff, a black male, filed his complaint against defendant,2 alleging that he was hired by defendant in 1994 but terminated by defendant on June 15, 2018. Plaintiff maintained ELCRA claims for (1) race discrimination resulting in his termination, (2) retaliation, and (3) racially hostile work environment.

On January 4, 2022, defendant moved for summary disposition pursuant to MCR 2.116(C)(10). In the accompanying brief, defendant argued that plaintiff’s race-discrimination claim fails because “[t]here is no evidence showing that the decision-maker (who is also African- American and who Plaintiff plainly testified did not discriminate against him) was predisposed to discriminate or that similarly situated employees outside of Plaintiff’s protected class were treated more favorably under similar circumstances.” In addition, defendant argued that “Plaintiff cannot demonstrate that GM’s legitimate reason for his termination—its investigation concluding he sexually harassed a subordinate—was pretext for race discrimination.” With regard to the retaliation claim, defendant argued that plaintiff “did not engage in any legally protected activity.” Finally, with regard to the hostile-work-environment claim, defendant argued that the alleged events “do not rise to the level of being sufficiently severe and pervasive,” and plaintiff cannot demonstrate that defendant had notice of the alleged harassment.

The documents attached to defendant’s motion for summary disposition indicated the following facts. On March 21, 2018, an anonymous complaint was lodged against plaintiff through “GM Awareline,” which stated, in relevant part:

Chassis 2 GROUP LEADER Aaron L. Minner is aggressive, argumentative, unprofessional, crude, a liar, disrespectful, and hostile attitude towards employees. He yells at employees. . . . He is lazy and sleeps at his desk about 3-4 nights per week between 3:30 a.m. and 5:30 a.m. . . . He needs to be held accountable for his actions instead of moved from area to area. His behavior needs to be investigated.

Investigation of the complaint was assigned to Marci Laurencelle, a salaried investigator for several plants operated by defendant. Laurencelle began her investigation by questioning business manager Mike Templeton about plaintiff. Templeton opined that plaintiff was aggressive and unprofessional. Laurencelle then questioned Menzo Dodge, an employee under plaintiff’s supervision, about plaintiff. Dodge similarly opined that plaintiff was aggressive and unprofessional. Laurencelle’s interview notes included the following entry about what she was told by Dodge:

Harassment, hourly employee [HP], Aaron is trying to get in her pants real hard. It’s not the first time, she is afraid to go to labor. He wants to meet her July 18th over shut down. She is scared she won’t get days off. He walks by her and shows 1 finger, 2 fingers and three fingers, and he asked her what that met [sic] and she said he said he likes three things, perfume, panties and pussy. She fears

2 The complaint also identified Robin Dugger as a plaintiff, but her race-discrimination claim against defendant was severed by the trial court. Jeff Lugger, who was originally named as a co- defendant, was later dismissed by the trial court as well. We will thus refer to General Motors LLC as the singular “defendant.”

-2- retaliation, she is a single mom and needs days off and is scared if she reports it he won’t approve her time off.

Laurencelle consequently interviewed HP. Laurencelle’s interview notes indicate that HP reported that plaintiff “made the comments that he likes the three P’s,” that plaintiff would frequently ask her to meet him outside of work, that plaintiff “makes me feel uncomfy,” and that plaintiff told her on one occasion that she “needed a shot of peniscilan.” HP said that she did not report plaintiff’s harassment of her before that interview because she was afraid of losing her job.

Laurencelle also interviewed Jeff Lugger, a superintendent. Lugger reported that plaintiff repeatedly had payroll issues, that plaintiff had a “letter to file” for an altercation with Templeton in 2017, and that plaintiff “basically said that [Lugger] was a racist” when Lugger said that he needed to arrive earlier to begin his shift.

Laurencelle interviewed Michelle Blalock, a salaried employee. Blalock said that HP told her about plaintiff and that she considered reporting the issue to the company on HP’s behalf, but she decided against doing so because HP “has a flirty personality.” Blalock added that HP did not specifically indicate whether the comments from plaintiff were unwelcome.

Finally, Laurencelle interviewed plaintiff. Laurencelle was joined by Vinita Evans, an HR supervisor. Plaintiff told Laurencelle and Evans that he was unaware of the meaning of “the three P’s” and indicated that he did not harass HP. Plaintiff implied that HP was lying for an unknown reason, and he did not believe that she had issues with people of color.

On March 26, 2018, Laurencelle submitted her investigation report to defendant. Laurencelle found that “[t]he allegation that Minner has been aggressive and hostile toward hourly and salaried employees is substantiated,” that “[t]he allegation that Minner sleeps at work is substantiated,” that “[t]he allegation that Minner mishandled employees pay is substantiated,” and “[t]he allegation that Minner sexually harassed [HP] is substantiated based on witness statements.”

Shortly thereafter, in June 2018, Evans, the sole decision-maker, decided to terminate plaintiff. Evans testified at her deposition that her decision only was based upon “the investigation of the sexual harassment. Anything that had to do with pay cards, him sleeping on the job, you know, him yelling and screaming at people, that was not considered at all.” Evans believed that the results of the investigation were accurate, and as a black woman she was “very ticked off” that plaintiff would suggest that he was terminated because he is black. Evans explained that she previously had terminated the employment of a white employee for circulating a “skinhead e-mail” because that employee, like plaintiff, violated the company’s anti-harassment policy.

Plaintiff, in his deposition, explained that he was employed as a “group leader” supervising hourly employees when he was terminated. Plaintiff stated his belief that Evans did not

-3- discriminate against him, harass him, act in a racially biased way against him, or retaliate against him.3 Plaintiff also stated his belief that there was “white privilege . . . on the floor.”

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Bluebook (online)
Aaron Minner v. General Motors LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aaron-minner-v-general-motors-llc-michctapp-2024.