Black v. Ohio Industrial Commission

CourtDistrict Court, S.D. Ohio
DecidedSeptember 12, 2023
Docket2:21-cv-02987
StatusUnknown

This text of Black v. Ohio Industrial Commission (Black v. Ohio Industrial Commission) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Black v. Ohio Industrial Commission, (S.D. Ohio 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

Rachael Black, Case No: 2:21-cv-2987 Plaintiff, Judge Graham v. Magistrate Judge Jolson State of Ohio Industrial Commission, et al., Defendants. Opinion and Order Plaintiff Rachael Black brings this employment discrimination suit relating to her removal from the position of Chief Legal Counsel for the State of Ohio Industrial Commission. Ms. Black, who is Puerto Rican, asserts claims under Title VII of the Civil Rights Act of 1964 for gender discrimination and national origin discrimination. She also asserts a claim under the Equal Pay Act. Defendants are the Ohio Industrial Commission and its Chairperson James Hughes and Executive Director Timothy Adams. This matter is before the Court on defendants’ motion for summary judgment. Defendants argue that plaintiff’s discrimination claims fail because Hughes had a legitimate, non-discriminatory reason to revoke Black’s appointment as Chief Legal Counsel. They argue that plaintiff’s Equal Pay Act claim fails because she received a higher rate of pay than the man who succeeded her. For the reasons stated below, the Court grants defendant’s motion for summary judgment. I. Background A. Facts The Ohio Industrial Commission was created to provide a forum for the adjudication and resolution of disputed workers’ compensation claims. See O.R.C. § 4121.02(A). The Commission is comprised of three members appointed by the Governor, with the consent of the Ohio Senate. See id. One member serves as the Chairperson, at the pleasure of the Governor, and is the head of the Commission. See O.R.C. § 4121.03(A). The Chairperson has the authority to hire hearing officers and staff and to appoint an Executive Director, who manages the Commission’s day-to-day operations. See O.R.C. § 4121.03(B), (C). The daily operations include supervising the hearing officers who resolve claims and determine eligibility for disability benefits. Black began her employment with the Commission in 1993 and served as a hearing officer for many years. In October 2013, she was appointed to Chief Legal Counsel by then-Chairperson Thomas Bainbridge. See Doc. 53-8 at PAGEID 913. Her initial rate of pay as Chief Legal Counsel was $48.12 per hour. See Doc. 53-7 at PAGEID 907. The position of Chief Legal Counsel is in Ohio’s unclassified civil service. See Ohio Rev. Code § 124.11(A)(9); Doc. 53-8 at PAGEID 915; Colasurd Aff., ¶ 5. It is undisputed that the position was at will and at the pleasure of the Chairperson. See Black Dep. at 124; Hughes Aff., ¶ 6. Black’s job duties included ensuring the Commission’s compliance with applicable law, making recommendations to the Chairperson, assigning hearing officers to matters, and acting as a liaison to the Bureau of Workers’ Compensation. See Doc. 53-8 at PAGEID 914–915; Feb. 15, 2023 Black Aff., ¶ 5; Black Dep. at 236–241. Plaintiff alleges that during the first three years of her tenure as Chief Legal Counsel, certain co-workers referred to her Puerto Rican national origin in a demeaning manner. Namely, defendant Adams and two directors, Jacob Bell and Michael Tanner, referred to her as “the Rican.” They did so outside of her presence. Black became aware of the matter when other employees told her about it. See Black Dep. at 98, 100, 101. Black testified that Tanner also said, “You’re going Rican,” directly to her during a disagreement. Id. at 82. Black believes that Tanner used the phrase to mean that she was getting “fired up” or upset. Id. Black further testified that she was told that Adams, outside of her presence, used the phrase “going Rican” in reference to her. Id. at 90, 96. Adams denies that he made any such comment about Black. See Adams Aff., ¶ 3. Black’s tenure as Chief Legal Counsel came to an end in late July 2019. See Doc. 53-5 at PAGEID 902. This occurred shortly after defendant Hughes became the Commission’s new Chairperson. Hughes had served as a legislator in both the Ohio House of Representatives and Ohio Senate. See Hughes Aff., ¶¶ 2, 4. When Mike DeWine became Governor in 2019, Hughes decided that he would pursue an appointment as head of an executive agency. See Hughes Dep. at 11. He first interviewed for a position with the Department of Insurance and then for the Industrial Commission. See id. at 11–12. Hughes had pre-determined that if he received an executive appointment he would hire James Burkart as his chief legal counsel. See id. Hughes had received advice from a mentor that, if he were to receive such an appointment, he should hire legal counsel whom he knew and trusted. See id. at 12. Hughes had known Burkart for about 20 years and was friends with him. See id. at 10. Hughes believed that Burkart had the right background experience, and another attorney whom Hughes knew had “highly recommended” Burkart for a chief legal counsel position. Id. at 11. Hughes testified in his deposition, “So before I even came into the Industrial Commission, I knew I was going to bring him [Burkart] in, wherever I went with the State, as my legal counsel.” Id. at 12. Hughes had never met Black prior to being appointed as Chairperson. See id. at 11. Governor DeWine appointed Hughes as Chairman of the Commission effective July 1, 2019. See Hughes Aff., ¶ 1. Hughes met with Black on July 11, 2019 to review “current actions pending before the courts and administrative agencies.” March 7, 2023 Black Aff., ¶ 8. According to Black, Hughes became sidetracked on the topic of former director Jacob Bell, who had been terminated for intimidating female employees. Hughes expressed his opinion that the internal investigation conducted of Bell was “unfair” and that he wanted to give Bell his job back. Id. Over the following two weeks, Black had a couple of interactions with Hughes. Black states that on one occasion, Hughes disagreed with a recommendation she had made and called her “incompetent.” Id., ¶ 9. On another occasion, around July 17, Hughes met with Black to discuss “how he could develop a working relationship with the two other Commissioners.” Id., ¶ 10. Hughes reported to Black that he had been told by Adams that “their demeanors were ‘difficult.” Id. When Black said that she worked well with the other two Commissioners, both of whom were women, Hughes responded that it was because Black was a female. Id. On July 25, Hughes met with Black and informed her that he was revoking her appointment as Chief Legal Counsel. Id., ¶ 11; Hughes Aff., ¶ 6. According to Hughes, he hired Burkart because he trusted him and because he was qualified for the job. Id., ¶ 7. The decision had “nothing to do with [Black’s] sex/gender or national origin.” Id., ¶ 6. When informed of Hughes’s decision, Black stated that she wanted to exercise her “fall-back rights” to return to her position as a hearing officer. See Black Dep. at 112; Hughes Dep. at 22. Hughes offered that he would reach out to an individual in the Governor’s office to help her if she wanted to pursue a legal counsel position with another agency. See Black Dep. at 112–113; Hughes Dep. at 22. Black contends that in the July 25 meeting Hughes opposed her assertion of fall-back rights on the grounds that she “did not have such rights.” March 7, 2023 Black Aff., ¶ 11. Hughes allowed Black to take Friday, July 26 off work to consider her options. See Black Dep. at 115; Hughes Dep. at 22.

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Black v. Ohio Industrial Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/black-v-ohio-industrial-commission-ohsd-2023.