Baker v. Rock Region Metropolitan Transit Authority

District Court, E.D. Arkansas·Decided November 29, 2023·No. 4:22-cv-00377·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

CORRY W. BAKER PLAINTIFF

V. 4:22CV00377 JM

ROCK REGION METROPOLITAN TRANSIT AUTHORITY D/B/A ROCK REGION METRO DEFENDANT

ORDER Pending is Defendant’s motion for summary judgment. (Docket # 19). Plaintiff filed an untimely response, however, the Court will consider it. Defendant filed a reply and the matter is ripe for determination. Plaintiff filed this civil rights action against his employer on April 25, 2022. Plaintiff, an African American male, was employed by the Defendant for fourteen (14) years. He was allegedly suspended from his position on July 29, 2021 and subsequently discharged on August 11, 2021 for not wearing his seatbelt. Plaintiff claims that at the time he was suspended he was on leave pursuant to the Family Medical Leave Act (“FMLA”). He alleges that Defendant violated his rights under the FMLA and discriminated against him on the basis of race in violation of Title VII, 42 U.S.C. § 2000e et seq., and 42 U.S.C. §1981. Facts Plaintiff has admitted each of the Defendant’s statement of undisputed facts and has submitted his own statement of disputed facts. Defendant Rock Region Metropolitan Transit Authority d/b/a Rock Region METRO (“METRO’) is the public transportation provider for central Arkansas. In 2007, METRO hired Plaintiff, an African American male, as a Fixed Route Bus Operator. In that capacity, Plaintiff was responsible for safely operating a bus along a fixed route, picking up and dropping off passengers and ensuring fares are paid. From February 2018 until his termination in August 2021, Plaintiff was supervised by METRO Operations Manager John Bohannon. Bohannon was supervised by METRO Operations Manager Donna Bowers. Both Bohannon and Bowers had the authority to discipline Fixed Route Operators. Plaintiff acknowledges that over his fourteen-year tenure with METRO, he was never attacked or

otherwise injured by a passenger while operating a METRO bus. METRO’s unionized workforce is represented by Local 704 of the Amalgamated Transit Union (the Union). The collective bargaining agreement entered between METRO and the Union on August 23, 2018 permitted METRO to “make reasonable rules and regulations regarding [its] operations, and the concurrent right to monitor employee compliance with said rules and regulations, and to discipline or discharge for just cause if violations occur.” Additionally, METRO had the “right to cause compliance with all applicable local, state, and Federal laws and regulations that apply to [it] and/or its employees,” and its bargained-for employees are obligated to follow those laws and regulations. At all times relevant to this case METRO required all of its

bus operators to wear a seatbelt while operating a METRO bus. Plaintiff was aware of this policy. On October 9, 2020, Plaintiff was involved in a motor-vehicle collision while driving his bus. METRO pulled video footage from the bus, pursuant to its policies and as is its right under the CBA to review footage of accidents, incidents, and complaints involving its buses and operators. While METRO determined Plaintiff was not at fault for the collision, the video showed Plaintiff driving his bus while not wearing a seatbelt in violation of METRO policy and the law. On October 23, 2020, Plaintiff received verbal coaching for violating the seatbelt policy and was cautioned that further seatbelt violations would subject him to progressive discipline. On December 17, 2020, METRO received a complaint from a passenger that Plaintiff was driving his bus without wearing a seatbelt. METRO again pulled and reviewed the video footage and confirmed that Plaintiff was driving the bus without wearing a seatbelt. On January 5, 2021, METRO issued Plaintiff a written Instruction for violating the seatbelt policy and cautioned him that further seatbelt violations would subject him to progressive discipline.

On January 18, 2021, the Union filed a grievance on Plaintiff’s behalf, stating “Mr. Baker feels the seat belts are inadequate protection for drivers because some seat belts get stuck some doesn’t work properly and passengers has attacked drivers while stuck in seatbelts Mr. Baker has wrote up seat belts and still have the same issue.” The Union asked METRO to “remove the instruction from Mr. Baker and correct the seat belts that could pose a threat to the drivers.” METRO held a Step One meeting on March 2, 2021, at which Baker’s Union Representative argued that “it was petty of METRO for Corry to get in trouble for not wearing his seatbelt . . . [and without providing specifics] that sometimes seatbelts don’t work property and they are written up to be repaired.” On March 8, 2021, METRO denied Plaintiff’s grievance.

On May 17, 2021, Plaintiff was involved in a second motor-vehicle collision while driving his bus. METRO pulled and reviewed video footage of the incident, which showed Plaintiff operating the bus while not wearing a seatbelt. On June 1, 2021, Plaintiff was issued a written Warning and was cautioned that additional seatbelt violations would subject him to progressive discipline, including suspension and/or termination. Plaintiff did not grieve the written Warning. On June 17, 2021, METRO received a report from a rider that Plaintiff was operating his bus while not wearing a seatbelt on June 15, 2021. METRO pulled and reviewed video footage from that day and observed Plaintiff operating his bus while not wearing a seatbelt. Plaintiff received a one-day suspension without pay and was informed that additional seatbelt violations would result in progressive discipline, up to and including termination. On June 19, 2021, the Union filed a grievance on Plaintiff’s behalf, arguing again that the seatbelts are too dangerous to wear while operating a METRO bus. During the same month, METRO conducted a seatbelt check on all buses, all of which had functional seatbelts with no

issues. On July 28, 2021, while the grievance related to Plaintiff’s suspension was still pending, METRO received a complaint from a passenger about an interaction that occurred with Plaintiff on his bus. METRO pulled and reviewed the video footage of the incident and observed Plaintiff operating his bus without wearing a seatbelt. On July 29, 2021, Plaintiff took intermittent FMLA leave due to a gout “flareup.” Several years prior to his termination, Plaintiff was diagnosed with gout in his foot, which would flare up unpredictably and cause debilitating pain. Plaintiff successfully applied to be certified for intermittent FMLA leave because of his gout attacks and took his full allotted twelve weeks of intermittent leave in 2019, and again in 2020. At some point, METRO contracted with a third

party to handle the administration of FMLA claims, but Plaintiff was never denied intermittent FMLA leave when he requested it, other than when he had already fully exhausted his allotted leave. On July 30, 2021, Plaintiff was placed out of service pending a probable discharge hearing for his fifth violation of the seatbelt policy. On August 5, 2021, METRO held Plaintiff’s probable discharge hearing, with Plaintiff and his Union representatives present. At the hearing, Plaintiff argued his seatbelt nonuse should be excused because other unnamed METRO drivers had unspecified instances of getting stuck in seatbelts, which would be a safety hazard if he was ever attacked by a passenger. During his tenure at METRO, Plaintiff had never been attacked or injured by a passenger. Following the probable discharge hearing, METRO terminated Plaintiff’s employment based on his persistent violations of the seatbelt policy.

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Baker v. Rock Region Metropolitan Transit Authority, (E.D. Ark. 2023).

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