Harris v. Hyundai Motor Manufacturing Alabama, LLC

District Court, M.D. Alabama·Decided June 16, 2021·No. 2:19-cv-00919·Unknown

Opinion

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE

MIDDLE DISTRICT OF ALABAMA, NORTHERN DIVISION

ELRICK HARRIS, ) ) Plaintiff, ) ) CIVIL ACTION NO. v. ) 2:19cv919-MHT ) (WO) HYUNDAI MOTOR ) MANUFACTURING ALABAMA, ) LLC, ) ) Defendant. )

OPINION In March 2019, plaintiff Elrick Harris was terminated from his position as a track driver with defendant Hyundai Motor Manufacturing Alabama, LLC. He brought suit, asserting he had been subject to discrimination and retaliation by the company. Harris alleges eight separate counts: age discrimination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. § 621 et seq.; disparate treatment on the basis of race in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 1981a and 2000e through 2000e-17; retaliation in violation of Title VII; discrimination on the basis of race in violation of the Civil Rights Act of 1866, as

amended, 42 U.S.C. § 1981; retaliation in violation of § 1981; interference with his benefits under the Family and Medical Leave Act (FMLA) of 1993, 29 U.S.C. § 2601 et seq.; retaliation under the FMLA; and intentional

infliction of emotional distress (also known as the tort of outrage) under Alabama law. Jurisdiction is proper pursuant to 28 U.S.C. §§ 1331 (federal

question), 1343 (civil rights), and 1367 (supplemental). Hyundai has filed a motion for summary judgment, arguing that Harris was fired for falsifying documents

and that there was no consideration of his race, his age, or his use of FMLA leave in the decision to terminate him. For the reasons below, the court will grant this motion as to each of the eight counts in the

complaint.

2 I. SUMMARY-JUDGMENT STANDARD Summary judgment is appropriate “if the movant

shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). To determine whether a genuine factual dispute exists, the court

must view the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in favor of that party. See Matsushita Elec. Indus.

Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). However, “conclusory assertions,” without admissible supporting evidence, “are insufficient to withstand summary judgment.” Holifield v. Reno, 115 F.3d 1555,

1564 n.6 (11th Cir. 1997), abrogated on other grounds by Lewis v. City of Union City, 918 F.3d 1213 (11th Cir. 2019) (en banc). In general, summary judgment is appropriate when “the record taken as a whole could not

lead a rational trier of fact to find for the non-moving party.” Matsushita, 475 U.S. at 587.

3 Summary judgment “applies in job discrimination cases just as in other cases. No thumb is to be placed on

the scale.” Chapman v. AI Transport, 229 F.3d 1012, 1026 (11th Cir. 2000) (en banc).

II. BACKGROUND

The parties agree on the general facts relevant to this case. Harris is a black man in his 60s. He was hired by

Hyundai in 2005 and worked at the company’s Montgomery, Alabama facility. At the time of his termination, he worked as a “track driver,” testing newly produced cars to ensure that they functioned properly. Hyundai

assigns a certain point value to different tests a track driver performs on a car, and the drivers are required to record which cars they tested and the number of points they received on a track card. These

track cards are then provided to the company.

4 Harris details numerous issues he had with his previous supervisor, Rocky Long. He alleges that these

stem from his participation in the company’s internal investigation of a racial discrimination claim against Long brought by one of his coworkers, Pamela Bryant. After Harris participated in the investigation, he

says, Long began criticizing and harassing him, including making comments about his race. Long ultimately moved to another position within the company

in which he no longer supervised Harris. In 2018, Harris’s new supervisor, Patrick Elliott, found a discrepancy in Harris’s track cards. He determined that Harris had claimed the same number of

points for running the same tests on the same car as another employee, which he found unlikely because the car had only been tested one time. After discovering this inconsistency, Elliott reviewed several of

Harris’s other track cards and found several other instances of point-counting he found to be

5 questionable. He also reviewed the track cards for other employees on his shift and found no other

instances of employees claiming points for tests they had not run. Elliott provided this information to his supervisor, who forwarded it to Team Relations, the division within Hyundai responsible for investigations

into employee misconduct. Team Relations employees investigated the allegation and produced a memorandum summarizing what

they found. They provided this memorandum to the Employee Review Committee, which reviews and discusses the findings of an investigation, and to Human Resources Manager Scott Gordy, who was responsible for

making the ultimate decision about whether or not to discharge an employee. Relying exclusively on the memorandum produced by Team Relations, Gordy concluded that Harris had deliberately falsified his track cards

several times over a period of months and decided to terminate him. Harris was notified by letter of his

6 termination in March 2018. He filed a charge of age and race discrimination with the Equal Employment

Opportunity Commission, or EEOC, in March 2019, within a year of his termination, and he received a dismissal and notice of rights in August 2019.

III. DISCUSSION A. ADEA Claim The Age Discrimination in Employment Act prohibits

employers from discriminating against any individual with regard to the terms, conditions, or privileges of employment because of his age. See 29 U.S.C. § 623(a)(1). Any individual over the age of 40 is a

member of the class protected under the ADEA. See id. at § 631(a). When an age-discrimination claim is based on circumstantial evidence,1 as Harris’s is, the McDonnell

1. The Eleventh Circuit defines “circumstantial evidence” as evidence that “suggests, but does not prove, a discriminatory motive.” Fernandez v. Trees, Inc., 961 F.3d 1148, 1156 (11th Cir. 2020) (internal 7 Douglas analysis applies. See McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Under this approach,

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