Equal Employment Opportunity Commission v. Michelin North America, Inc.

47 F. Supp. 2d 984, 1999 U.S. Dist. LEXIS 6999, 82 Fair Empl. Prac. Cas. (BNA) 665
CourtDistrict Court, N.D. Illinois
DecidedApril 30, 1999
DocketNo. 98 C 5077
StatusPublished

This text of 47 F. Supp. 2d 984 (Equal Employment Opportunity Commission v. Michelin North America, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Equal Employment Opportunity Commission v. Michelin North America, Inc., 47 F. Supp. 2d 984, 1999 U.S. Dist. LEXIS 6999, 82 Fair Empl. Prac. Cas. (BNA) 665 (N.D. Ill. 1999).

Opinion

MEMORANDUM OPINION AND ORDER

CASTILLO, District Judge.

The Equal Employment Opportunity Commission (“EEOC” or “the Commission”) filed this lawsuit on behalf of Karen Bodie, a former employee of Michelin North America (“Michelin”). The Commission alleges that Michelin fired Bodie in retaliation for engaging in protected conduct, and Michelin now seeks summary judgment. The EEOC has produced evidence establishing a genuine issue whether Michelin fired Bodie because she filed a sex discrimination charge with the EEOC. Therefore, we deny Michelin’s motion for summary judgment (19-1).

FACTS1

In 1989, Michelin hired Bodie as a territory sales manager for the Chicago region. [985]*985Following the birth of her child in February 1994, Bodie’s supervisor Bob Phaneuf began harassing her. Initially, she simply sought a transfer from the Chicago District to Peoria in the St. Louis District, but eventually, in August 1994, she filed an EEOC charge for sex discrimination.

Michelin, instead of investigating Bodie’s claims against Phaneuf, began investigating Bodie. Specifically, in October 1994, Human Resource Manager Todd Gillespie ordered Bodie to undergo psychological testing; reviewed all of Bodie’s past expense reports, company credit card bills, and cellular phone bills; and opened a file of his own handwritten notes on Bodie. Although his October investigation of her expense documents revealed no problems, he conducted another such review at the end of January 1995. Again, he discovered no improprieties. On the other hand, Gillespie neither asked Phaneuf about Bodie’s charges, nor questioned co-workers who witnessed interactions between Bodie and Phaneuf. Moreover, although a sales position in Peoria became vacant during this time, it was not offered to Bodie; instead, she was offered a transfer to Fargo, North Dakota; Des Moines, Iowa; or Oklahoma City, Oklahoma.

On February 7, 1995, Michelin conducted a fairness hearing, during which Pha-neuf surprised everyone by admitting the alleged discriminatory conduct. Phaneuf was fired five days later, and Gillespie began settlement negotiations with Bodie. On March 31, 1995, an agreement was signed, (EEOC Ex. 14, Settlement Agreement and Release); Bodie relinquished her claims against Michelin in exchange for a transfer to Peoria.

While working in Peoria, Bodie’s supervisor was Jim Cavanaugh. Although Bod-ie started working in the St. Louis District toward the end of March, she did not meet Cavanaugh until April 17. At that meeting, Cavanaugh asked Bodie “what the deal was” with Phaneuf. Bodie says that she immediately changed the subject because, the settlement agreement prohibited her from disclosing its circumstances.. She suspected that Cavanaugh was trying to trick her into violating the agreement so that Michelin could fire her.

On June 26, 1995, Michelin did in fact fire Bodie and, now, points to three reasons supporting its decision. (EEOC Ex. 24, Gillespie Memorandum to Bodie’s File.) The first reason was insubordination. In April, Cavanaugh apparently told the Peoria sales team that they were required to use a specific Michelin-sanctioned bag when making sales calls. Bodie purchased (and charged on her expense report) a second bag to use in conjunction with the Michelin-sanctioned bag. She did not understand Cavanaugh’s statement about using the Michelin bag as precluding the use of an additional bag, although this is what Cavanaugh intended. Cavanaugh interpreted Bodie’s purchase of the second bag as evidence of disrespect and called Gillespie, who advised him to document the incident and disallow the expense.

The second reason given for firing Bodie is that she falsified her May expense report. On May 30, Bodie checked into a Holiday Inn in Effingham, Illinois. She had lunch and dinner at the .hotel. On her expense report, (EEOC Ex. 20, June 6, 1995 Expense Report), she claimed $8.75 for lunch and $23.90 for dinner. However, she submitted the top portion of a hotel receipt for $12.94 and the bottom portion of the same receipt with $23.90 written on it. Cavanaugh did not confront Bodie with the discrepancy. Instead, he called Gillespie. In turn, Gillespie’s notes suggest that he instructed Cavanaugh to research Bodie’s other expenses (for example, her cellular phone bills, credit card bills, and “calls made vs claimed”) and then called Michelin’s legal department. (EEOC Ex. 10 at [986]*986D00425, Gillespie Notes, undated.) Cava-naugh received the records necessary to complete his research project on June 22. Again, Cavanaugh did not confront Bodie with the problem until the day he and Gillespie fired her. Finally, Michelin claims it fired Bodie because she double billed $23.20 in phone calls and made excessive personal calls while on the road that she charged to Michelin.

Ten days prior to her discharge, Cava-naugh completed a performance evaluation of Bodie. (EEOC Ex. 18, Bodie’s Development Progress Review of June 16, 1995.) In the evaluation Cavanaugh does not report any of the problems Michelin allegedly relied upon to fire her, even though he and Gillespie had identified the three issues by the time Cavanaugh wrote the review. He also did not confront her orally when the two met to review the evaluation.

Cavanaugh arranged a meeting with Bodie on June 26, 1995, without revealing its purpose or that others would attend. But Cavanaugh cleared the date with Gillespie and Randy Gaetz, Michelin’s Vice President of Sales for North America, and, in fact, the three men discussed a “plan of attack” prior to the meeting. At the meeting, Cavanaugh and Gillespie confronted Bodie with the three problems they had identified during their previous conversations. Bodie first explained that she had lost the dinner receipt for May 30 and, therefore used the lower part of her lunch receipt to document the cost of her dinner. Second, she explained her misunderstanding of Cavanaugh’s instructions regarding the second bag, and noted that one of her co-workers, Mark Bierman, used a second bag identical to that purchased by Bodie, for which Michelin reimbursed him. Finally, she admitted mistakenly charging $23.20 in phone calls to two separate departments. The three men were unsatisfied with her explanations and fired her on the spot.

The EEOC claims that these facts establish Michelin’s retaliatory motivation for firing Bodie. Specifically, the Commission asserts that Gillespie was gunning for Bodie from the moment she filed her discrimination charge with the EEOC, and that he orchestrated the events that resulted in her discharge. Michelin, on the other hand, argues that Cavanaugh fired Bodie and that he could not possibly have had a retaliatory motive because he was unaware of Bodie’s protected activities. Moreover, according to Michelin, Cava-naugh was simply following Michelin’s zero-tolerance policy when confronted with an employee’s falsified expense report.

ANALYSIS

I. Procedural Issues

Initially, we must address two procedural issues. Michelin maintains that by signing the settlement agreement Bodie waived any claim she had against Michelin arising before March 31, 1995. Similarly, Michelin claims that the allegations in the EEOC’s complaint limit our consideration of events to those occurring after March 31, 1995. (Reply Br. at 2-3 (quoting Compl. at ¶ 7 (“Since at least March, 1995, Michelin has engaged in ...

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47 F. Supp. 2d 984, 1999 U.S. Dist. LEXIS 6999, 82 Fair Empl. Prac. Cas. (BNA) 665, Counsel Stack Legal Research, https://law.counselstack.com/opinion/equal-employment-opportunity-commission-v-michelin-north-america-inc-ilnd-1999.