Bennett v. Trinity Marine Products, Inc.

54 F. Supp. 3d 591, 2014 U.S. Dist. LEXIS 130988, 2014 WL 4674764
CourtDistrict Court, E.D. Louisiana
DecidedSeptember 18, 2014
DocketCivil Action No. 13-5816
StatusPublished

This text of 54 F. Supp. 3d 591 (Bennett v. Trinity Marine Products, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennett v. Trinity Marine Products, Inc., 54 F. Supp. 3d 591, 2014 U.S. Dist. LEXIS 130988, 2014 WL 4674764 (E.D. La. 2014).

Opinion

ORDER AND REASONS

MARTIN L.C. FELDMAN, District Judge.

Before the Court is Trinity Marine Products, Inc.’s motion for summary judgment. For the reasons that follow, the motion is GRANTED in part and DENIED in part.

Background

This employment discrimination lawsuit arises out of the plaintiffs claims that, upon his return from taking medical leave after suffering an aortic aneurysm, his former employer unlawfully failed to reinstate him to his prior position and then fired him in retaliation for exercising his rights under the Family and Medical Leave Act.

Trinity Marine Products, Inc. manufactures barges used to transport cargo on U.S. inland waterways. Ronald H. Bennett began working as a burner for Trinity at Plant 1038 in Madisonville, Louisiana in 1979. He gradually worked his way up to a management position.1 Bennett was promoted to Production Manager in 2011 by then — Plant Superintendent Sam Nara-more, who at that time was also Bennett’s supervisor.2 In particular, Bennett was tasked with managing the pipe and testing departments; he was responsible for overseeing welders and pipe fitters. In early 2012 Bennett received a “meets expectations” performance rating on his 2011 performance evaluation from Naramore. In September 2012 Rick Badon became the new Plant Manager. Shortly thereafter, Badon demoted Naramore to a Production Manager position due to performance-related issues.

[594]*594After a company picnic on October 22, 2012 Bennett suffered an aortic aneurysm. As a result, he took leave authorized by the Family and Medical Leave Act, starting at the end of October 2012. While he was out on FMLA leave, Tim Gay (another Production Manager) took over Bennett’s responsibilities including managing the pipe and testing departments. In fact, during this time that Bennett was on leave, Plant Manager Badon conducted a reorganization in which several production managers were reassigned to manage different departments.3

A few months later, Bennett’s treating doctor released him to return to work without restrictions; Bennett returned to Trinity in February 2013. Bennett resumed his prior position as Production Manager, and his pay, benefits, and overall management duties remained the same as those prior to his FMLA leave. However, Tim Gay continued to oversee Bennett’s previously-assigned department, the pipe department and, in part, the testing department. As Production Manager, Bennett continued to bear responsibility for managing a 28-man crew, developing budgets, and overseeing completion of the barges for delivery; he was, however, tasked with overseeing different departments, the cleaning and painting departments, although he continued to manage the hydro and testing departments.4

After Bennett returned from leave (after Deese replaced Naramore as Plant Superintendent), Deese counseled Bennett regarding his job performance.5 In particular, Deese complained that barges were not being sufficiently cleaned, were not being completed for on-time delivery, and that the proper procedures for hydro testing were not being followed. Bennett suggests that he was not disciplined for these purported performance deficiencies, and explains away these complaints as examples of him being targeted for discipline for issues that were not his fault, including because members of his crew were being reassigned to work for other Production Managers, compromising Bennett’s department’s ability to accomplish its tasks.6

In addition to these purported performance deficiencies, Bennett was also reprimanded for failing to timely submit written evaluations for his direct reports; submitting an evaluation for one of his direct reports which contained grammatical errors and an allegedly improper comment regarding his subordinate’s weight; refusing to revise the evaluation and correct the errors; showing a lack of professionalism at business meetings (taking personal calls and checking facebook during meetings). Bennett does not deny [595]*595that he was reprimanded for these issues. But he disputes the merits of the underlying complaints, and explains: according to the email reminding him to submit his performance evaluations, other individuals had more evaluations outstanding than Bennett; the comment in his evaluation regarding his subordinate’s weight was not improper because the workers work in confined spaces; managers regularly use their cell phones on the job and Bennett used his cell phone for proper purposes (to communicate with his crew) and was never disciplined.

On June 26, 2013 Bennett was issued an Employee Action Plan, which listed Bennett’s purported performance deficiencies, noted his failure to utilize his crew efficiently, and cautioned “we are placing you on an action plan, we MUST see immediate improvement in key areas [outlined in the plan].” Bennett admits to receiving the Action Plan, but again disputes his responsibility for the purported deficiencies it outlines.

Early on the morning of July 16, 2013, one of Bennett’s direct reports, Roy Priser, was scheduled to work, but called in sick, stating that he had a kidney stone. (Bennett does not dispute that Priser was scheduled to work but called in sick.) Bennett entered a payroll code of “No Work-Not Dispatched”, a code which indicated that Priser was not on the July 16 schedule; as such, the day would not be counted against Priser in terms of bonus consideration. According to formal company policy, this was a falsification related to payroll or time-keeping, which is a major infraction and first-time terminable offense.7

Two days later on July 18 Bennett was placed on suspension pending investigation. Four days later on July 22 Trinity terminated Bennett’s employment based on his poor performance and his failure to improve under the terms of the Employee Action Plan.8 Rick Badon made the decision to fire Bennett based on the information and documents provided by Kevin Deese and HR Manager Diane Boudreaux. Trinity did not hire anyone in place of Bennet; rather, Tim Gay subsumed Bennett’s duties and took over managing the departments previously managed by Bennett.9

[596]*596On September 12, 2013 Bennett sued Trinity, alleging claims under the Family Medical Leave Act as well as state law-based disability and age discrimination claims. Trinity now seeks summary judgment in its favor dismissing all claims.

I.

Federal Rule of Civil Procedure 56 instructs that summary judgment is proper if the record discloses no genuine dispute as to any material fact such that the moving party is entitled to judgment as a matter of law. No genuine dispute of fact exists if the record taken as a whole could not lead a rational trier of fact to find for the non-moving party. See Matsushita Elec. Indus. Co. v. Zenith Radio., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). A genuine dispute of fact exists only “if the evidence is such that a reasonable jury could return a verdict for the non-moving party.” Anderson v. Liberty Lobby, Inc.,

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Bluebook (online)
54 F. Supp. 3d 591, 2014 U.S. Dist. LEXIS 130988, 2014 WL 4674764, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-trinity-marine-products-inc-laed-2014.