Gracia v. Sigmatron International, Inc.

102 F. Supp. 3d 983, 2015 U.S. Dist. LEXIS 51838, 2015 WL 1841407
CourtDistrict Court, N.D. Illinois
DecidedApril 21, 2015
DocketNo. 11 C 07604
StatusPublished
Cited by3 cases

This text of 102 F. Supp. 3d 983 (Gracia v. Sigmatron International, 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
Gracia v. Sigmatron International, Inc., 102 F. Supp. 3d 983, 2015 U.S. Dist. LEXIS 51838, 2015 WL 1841407 (N.D. Ill. 2015).

Opinion

Order

Honorable Edmond E. Chang, United States District Judge

After a three-day trial in December 2014, a jury found in favor of Sigmatron International, Inc. on Maria Gracia’s claim that she had been the victim of workplace harassment, in violation of Title VII of the Civil Rights Act of 1964. But the jury did find that Sigmatron had unlawfully retaliated against Gracia by firing her after she complained about the allegedly discriminatory treatment, and awarded her $57,000 in compensatory and $250,000 in punitive damages. Sigmatron now moves for judgment as a matter of law on the retaliation claim under Federal Rule of Civil Procedure 50(b), or, in the alternative, for a new trial under Rule 59(a) and remittitur of the damages award under Rule 59(e). For the reasons described below, the motions for judgment as a matter of law and new trial are denied. The remittitur motion is granted only to the extent that the compensatory damages award is lowered to $50,000 to comply with a statutory, cap, which Gracia does not oppose.

I. Motion for Judgment as a Matter of Law

Sigmatron argues that judgment should be granted in its favor as a matter of law on Gracia’s retaliation claim under Rule' 50, which provides such relief where “a reasonable jury [lacks] a legally sufficient evidentiary basis to find for the [prevailing] party[.]” Fed.R.Civ.P. 50(a). In weighing a Rule 50(a) motion, “the question is simply whether the evidence as a whole, when combined with all reasonable inferences permissibly drawn from that evidence, is sufficient to allow a reasonable jury to find in favor of the plaintiff.” Hall v. Forest River, Inc., 536 F.3d 615, 619 (7th Cir.2008) (citing Hossack v. Floor Covering Assoc. of Joliet, Inc., 492 F.3d 853, 859 (7th Cir.2007)). A jury’s determination may be overturned only if “no rational jury could have found for plaintiff,” and there must also be more than “a mere scintilla of supporting evidence.” Walker v. Bd. of Regents of Univ. of Wisconsin Sys., 410 F.3d 387, 393 (7th Cir.2005) (quoting Millbrook v. IBP, Inc., 280 F.3d 1169, 1173 (7th Cir.2002)). The court must “not make credibility determinations or reweigh the evidence,” and “must disregard all evidence favorable to the moving party that the jury is not required to believe.” Tart v. Illinois Power Co., 366 F.3d 461, 472 (7th Cir.2004).

Sigmatron argues that the evidence showed Gracia was fired for a legitimate reason: she improperly allowed hand sol[987]*987derers under her watch to use lead-free instead of leaded solder, in violation of customer specifications. R. 196, Def.’s Br. at 4-5. Sigmatron emphasizes evidence at trial about the importance the company-placed in meeting customer specifications, driven partly by regulatory and industry directives. Id. (citing inter alia testimony about company’s training on proper soldering and auditing procedures). Gregory Fairhead, Sigmatron’s vice president, testified that it was Gracia’s involvement in the solder discrepancy that led to her firing. R. 190, Trial Tr. at 370.1

Sigmatron relies heavily on this mistake in soldering, and it is true that, standing alone, the problem sounds serious. But Sigmatron does not come to grips with the fact that the jury had plenty of reason not to believe that the lead-free solder really drove the -company to fire Gracia. The jury heard testimony that, in reality, Sigmatron did from time to time — indeed even often — use solder types that did not fit client specifications, without any negative ramifications for the responsible employees. Gracia unsurprisingly testified to this effect. Trial Tr. at 463. Under the deferential standard applicable here, that testimony alone undermines Sigmatron’s asserted explanation. ;

But that is not all. Eduardo Trujillo, a former Sigmatron automation manager, also testified that this practice occurred “often,” yet nobody had ever been fired as a result. Id. at 557-59. There is more. Michael Murphy, a former Sigmatron engineér, also testified that leaded and lead-free solders were used interchangeably “a lot of [the] time,” irrespective of customer preference, in order to make do with whatever parts were available as a matter of company policy. Id. at 543-44 (adding that no one had ever been fired for switching leaded and lead-free solders). Sigma-tron’s reliance on customers’ solder specifications could well have struck the jury as pretextual in light of thé evidence that the company did not really care if errors were made at least before this lawsuit was filed.

It is true that, even if company managers had shrugged their shoulders at lax compliance in the past, it is still possiblé that Sigmatron belatedly chose to clean-up shop, starting with Gracia. Fairhéad testified that when he took over as director of operations in 2007, he sought to “tighten up.... certain things,” including manufacturing procedure. Id. at 396. But the jury was not obliged to credit that scenario when weighing the conflicting testimony from Fairhead and management (that is, the correct-solder- rule was life-and-death vital)- on the one hand, and from other managers and employees (that is, the purported rule was not enforced, ever) on the other. ,

Indeed, the jury had another reason to doubt Fairhead’s account. Fair-head testified at length about the events that purportedly led to Gracia’s firing: Trujillo discovered Gracia’s solder error, noted a cavalier indifference from Garcia when she was questioned about it, and then went to supervisor Patrick Silverman, all of which was reported to Fairhead. - Id. at 414-15. The problem is that Trujillo denied having any discussion with Silver-man at all about the soldering, let alone a discussion where Gracia displayed a cavalier attitude toward thé mistake. See id. at 556-57. And Trujillo, described the conversation with Fairhead as simply saying that Trujillo was aware of the mistake. Id. at 557. In light of the conflicting testimony, it was certainly .within the province of the jury, relying on its observations of [988]*988the various witnesses, to disbelieve Fair-head- and his assertion that he terminated Garcia on the basis of the solder inconsistency — a credibility determination that is reasonable.2 See Tart, 366 F.3d at 472 (court must be “particularly careful in employment discrimination cases to avoid supplanting [its] view of the credibility or weight of the evidence for that of the jury”) (citing Hybert v. Hearst Corp., 900 F.2d 1050, 1054 (7th Cir.1990)).

All told, “the jury heard evidence from which it could infer pretext]] and] just because [Sigmatron] articulated a nondiscriminatory reason, the jury did not have to believe it.” Emmel v. Coca-Cola Bottling Co. of Chicago, 95 F.3d 627, 633 (7th Cir.1996). Sigmatron relies entirely on the argument that the evidence could only show that its asserted rationale for firing Gracia was perfectly legitimate.3 As explained, that is not the case. Accordingly, Sigmatron’s motion for judgment as a matter of law is denied.

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Cite This Page — Counsel Stack

Bluebook (online)
102 F. Supp. 3d 983, 2015 U.S. Dist. LEXIS 51838, 2015 WL 1841407, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gracia-v-sigmatron-international-inc-ilnd-2015.