Douglas v. International Automotive Components Group North America, Inc.

483 F. App'x 178
CourtCourt of Appeals for the Sixth Circuit
DecidedJune 5, 2012
Docket11-1411
StatusUnpublished
Cited by5 cases

This text of 483 F. App'x 178 (Douglas v. International Automotive Components Group North America, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Douglas v. International Automotive Components Group North America, Inc., 483 F. App'x 178 (6th Cir. 2012).

Opinion

PER CURIAM.

Lawrence Douglas appeals a district court’s judgment dismissing his civil rights complaint filed pursuant to the Age Discrimination in Employment Act (ADEA), 28 U.S.C. § 621 et seq.

International Automotive Components Group North America, Inc. (IAC), an auto parts supplier, terminated Douglas’s employment. At the time of his termination, Douglas was fifty-seven years old. Douglas began working at the company’s Huron, Ohio plant in 2003, at which time it was owned by another corporation. He became an IAC employee in 2007. Douglas held various positions at the plant and was working as a quality engineer and lab manager when he was laid off. The layoffs occurred in response to a severe downturn in the automobile industry, which resulted in the imposition of various cost-cutting measures by IAC. Many of Douglas’s former duties were assumed by Matt Starling, a younger employee, who was transferred to the Huron plant from a facility in Plymouth, Michigan, where his position was slated to be eliminated.

Douglas filed his ADEA complaint alleging that he was discharged because of his age and that, after his discharge, he applied for positions at IAC for which he was not hired because of his age. The district court granted summary judgment to IAC, concluding that Douglas did not provide sufficient evidence to raise an issue of fact as to whether he was discharged because of his age. The district court also concluded that Douglas had provided no evidence *180 that IAC’s subsequent failure to rehire him was age related.

We review de novo the district court’s grant of summary judgment. Lefevers v. GAF Fiberglass Corp., 667 F.3d 721, 723 (6th Cir.2012).

Because Douglas bases his claim on circumstantial evidence, we apply the burden-shifting framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). See Geiger v. Tower Auto., 579 F.3d 614, 622 (6th Cir.2009). Under this framework, Douglas must first establish a prima facie case of age discrimination, which includes four elements: “1) that he was a member of a protected class; 2) that he was discharged; 3) that he was qualified for the position that he held; and 4) that he was replaced by someone outside of the protected class.” Id. When an employee is discharged as part of a workforce reduction, however, we modify the fourth element to require “additional direct, circumstantial, or statistical evidence tending to indicate that the employer singled out the plaintiff for discharge for impermissible reasons.” Id. at 623 (quotation marks and citation omitted).

If an employee makes this prima facie showing, “the burden of production shifts to the employer to articulate a legitimate nondiscriminatory reason for the adverse employment action.” Schoonmaker v. Spartan Graphics Leasing, LLC, 595 F.3d 261, 264 (6th Cir.2010). “If the employer meets this burden, the burden of production shifts back to the plaintiff to show that the employer’s explanation was a mere pretext for intentional age discrimination.” Id.

The district court found that Douglas failed to satisfy the fourth prong of his prima facie case because he was not replaced by Starling, and because he did not produce additional direct, circumstantial, or statistical evidence tending to show that he was discharged based on his age. Douglas challenges both conclusions on appeal, asserting that he was replaced by Starling and that, even if he was not, he presented sufficient additional evidence that he was singled out for discharge based on his age. We need not resolve the issue of whether Douglas was replaced by Starling. Even if we assume that Douglas established a prima facie case of age discrimination, he has failed to set forth evidence sufficient for a reasonable juror to find that IAC’s proffered reason for discharging him was pretextual. See Browning v. Dep’t of Army, 436 F.3d 692, 696 (6th Cir.2006).

There is no dispute that IAC decided to reduce its workforce because of a significant economic downturn and that it directed its plant managers, including Huron plant manager Charles Raymont, to effect a ten percent reduction in base wages. According to Raymont, he felt that Starling was critical to the upcoming launch of a project involving ethylene vinyl acetate (EVA) for carpet and was also able to perform Douglas’s duties. Consequently, when Raymont was informed that Starling’s position was slated for elimination, he made the decision to have Starling transferred to Huron and to lay off Douglas.

A plaintiff can “establish pretext by showing that the proffered reason (1) has no basis in fact; (2) did not actually motivate the adverse employment action; or (3) was insufficient to warrant the adverse action.” Sybrandt v. Home Depot, U.S.A., Inc., 560 F.3d 553, 558 (6th Cir. 2009) (citations and internal quotation marks omitted). A plaintiff may also establish pretext “by offering evidence which challenges the reasonableness of the employer’s decision to the extent that *181 such an inquiry sheds light on whether the employer’s proffered reason for the employment action was its actual motivation.” Id. (citation and internal quotation marks omitted). Douglas cannot show pretext using any of these methods.

Douglas first attempts to show pretext by arguing that the workforce reduction cannot be the true reason for his discharge because his position was not eliminated, but was filled by Starling. There is no dispute, however, that the “reshuffling” resulted in the elimination of a position and cost savings, “the goal of any [reduction in force].” Brocklehurst v. PPG Indus., Inc., 123 F.3d 890, 895 (6th Cir.1997). The case on which Douglas relies, Bonfiglio v. Mich. Underground Specialists, No. 09-13534, 2010 WL 3190829, at *5 (E.D.Mich. Aug. 12, 2010), is distinguishable because, in that case, a new employee was hired to replace the plaintiff at a higher wage. Further, the rationale offered by IAC for Douglas’s discharge in response to his lawsuit is consistent with the rationale set forth at the time that the decision was made. Accordingly, there is no merit to Douglas’s argument that IAC’s “shifting rationale” is evidence of pretext. Cf. Cicero v. Borg-Warner Auto., Inc., 280 F.3d 579, 591-92 (6th Cir.2002).

Douglas also attempts to show pretext by arguing that he was significantly more qualified than Starling and that Raymont did not have an adequate basis on which to conclude that Starling was more critical to the carpet EVA project.

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Bluebook (online)
483 F. App'x 178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/douglas-v-international-automotive-components-group-north-america-inc-ca6-2012.