JACKSON-NIBBS v. UNITED WAY OF CENTRAL INDIANA

CourtDistrict Court, S.D. Indiana
DecidedSeptember 20, 2021
Docket1:19-cv-03729
StatusUnknown

This text of JACKSON-NIBBS v. UNITED WAY OF CENTRAL INDIANA (JACKSON-NIBBS v. UNITED WAY OF CENTRAL INDIANA) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JACKSON-NIBBS v. UNITED WAY OF CENTRAL INDIANA, (S.D. Ind. 2021).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

TANGI JACKSON-NIBBS, ) ) Plaintiff, ) ) v. ) Case No. 1:19-cv-03729-TWP-MPB ) UNITED WAY OF CENTRAL INDIANA, ) ) Defendant. )

ORDER ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND PLAINTIFF'S MOTION FOR LEAVE TO FILE SURREPLY

This matter is before the Court on a Motion for Summary Judgment filed pursuant to Federal Rule of Civil Procedure 56 by Defendant United Way of Central Indiana ("United Way") (Filing No. 49). After her employment with United Way ended, Plaintiff Tangi Jackson-Nibbs ("Jackson-Nibbs") filed this action alleging race discrimination and retaliation against United Way pursuant to Title VII of the Civil Rights Act of 1964 ("Title VII") and the Civil Rights Act of 1871, 42 U.S.C. § 1981 ("Section 1981") (Filing No. 1). United Way filed a Motion for Summary Judgment on all of the claims, and following briefing, Jackson-Nibbs filed a Motion for Leave to File Surreply (Filing No. 65). For the following reasons, the Court grants United Way's Motion for Summary Judgment and denies Jackson-Nibbs' Motion for Leave to File Surreply. I. BACKGROUND The following facts are not necessarily objectively true, but as required by Federal Rule of Civil Procedure 56, the facts are presented in the light most favorable to Jackson-Nibbs as the non- moving party. See Zerante v. DeLuca, 555 F.3d 582, 584 (7th Cir. 2009); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). United Way is a nonprofit organization established in 1918 which strives to help Central Indiana residents achieve and maintain self-sufficiency by focusing on four key areas of community impact: education, financial stability, health, and basic needs. It serves residents in Boone, Hamilton, Hancock, Hendricks, Marion, and Morgan counties. United Way has partnered

with more than eighty local agencies and organizations to help improve the quality of life for Central Indiana residents (Filing No. 50-7 at 3–4). On September 8, 2014, Jackson-Nibbs, who is African-American, began working at United Way as an Energy Assistance Program ("EAP") Coordinator. EAP is a federally-funded grant program that provides financial assistance to low-income households to maintain utility services such as electricity and gas. Jackson-Nibbs' position was funded through the grant. As an EAP coordinator, she processed applications, conducted intake of applications, and met with clients to help them pay their utility bills. When she applied for the job, Jackson-Nibbs stated that she was willing to work overtime, including Saturdays. Throughout her employment, she reported to Mary Jones ("Jones"), the Director of EAP. Jones interviewed Jackson-Nibbs and made the

recommendation to Rick Tisdale ("Tisdale"), the Director of Human Resources, to hire her (Filing No. 50-1 at 8, 11–15, 21–22, 25–26, 196; Filing No. 50-3 at 7–9). The busy season for EAP was October through March, driven by colder temperatures and more applications for utilities assistance (Filing No. 50-3 at 21–22; Filing No. 50-4 at 22). EAP hired temporary employees to assist with processing applications during the busy season from approximately October to March. Because these were temporary employees, they did not receive performance reviews and were not held to the same performance standards as fulltime United Way employees. There was one other fulltime associate on the EAP team—Cherelle Prim ("Prim") who is African-American (Filing No. 50-7 at 2). Approximately four months after beginning her work at United Way, Jackson-Nibbs met with Jones on January 29, 2015, to discuss Jackson-Nibbs' mid-year performance evaluation and performance goals. Thereafter, Jones preformed an annual performance review of Jackson-Nibbs for the 2014–2015 year. Jones provided Jackson-Nibbs with individual scores on individual items

in this performance review, rather than an overall score, and she received scores of 3 or 4 out of 5. Jackson-Nibbs met her goals in the 2014–2015 review (Filing No. 58-18 at 10, 12; Filing No. 58- 2; Filing No. 58-20 at 21–23). However, in order to achieve these goals, Jackson-Nibbs often worked seven days a week, putting in an extreme number of hours (Filing No. 58-19 at 12). In less than a year from her start date, Jones made the decision to promote Jackson-Nibbs to the associate position in EAP, effective August 10, 2015. It was a salaried, exempt position. The promotion was due to United Way's review of the position and a determination that "associate" was a better description for the duties performed by Jackson-Nibbs. As an associate, Jackson- Nibbs' duties included planning, scheduling, coordinating, and training all intake specialists, case managers, and quality assurance specialists for EAP. It was also her responsibility to assign the

daily operations of intake and quality assurance team members to ensure tasks were completed in a timely and efficient manner; and to evaluate, monitor, and measure the performance of intake and quality assurance team members on EAP policies and procedures, including processing applications, reviewing applications, mail room, and front desk procedures (Filing No. 50-1 at 38– 39, 44–46, 250–53; Filing No. 50-3 at 15–16; Filing No. 50-4 at 32; Filing No. 50-5 at 21). Jones met with Jackson-Nibbs to deliver her 2015–2016 annual performance review. In this performance review, Jackson-Nibbs was given an average score of 3.6 out of 5 for United Way's core competencies, and an average score of 3.2 out of 5 for performance competencies. A score of "3" was considered "successfully meets expectations." After Jones delivered the annual review, Jackson-Nibbs electronically added comments and signed-off on the review. In her comments, Jackson-Nibbs explained that she would like to discuss changing her title from associate to manager because she felt that better reflected the work she performed. Jackson-Nibbs did not discuss this with Jones during the annual performance review meeting, and Jones was not

sent a notification about the additional comment being entered after the meeting. As a result, Jones was not aware of Jackson-Nibbs' comment at the time (Filing No. 50-1 at 53–54, 254–66; Filing No. 50-3 at 65–66; Filing No. 50-2 at 19). Jones and Jackson-Nibbs worked together to set Jackson-Nibbs' goals and action items for the 2016–2017 performance year. At United Way, an employee's goals were set at the beginning of each performance year and were communicated to each employee by their leader. Where a position was covered by a grant, often the grant itself helped determine the goals. For 2016–2017, Jackson-Nibbs' goal of providing high quality EAP services included the action items of retraining intake specialists as needed based on weekly quality assurance review scorecards, updating or creating procedures to minimize errors, and training the entire Indianapolis EAP team. The goal

was to audit at least 30% of applications and have an audited error rate below 7.6% (Filing No. 50-1 at 56–57, 267–68; Filing No. 50-4 at 48). In her 2016–2017 mid-year performance evaluation, Jackson-Nibbs received a rating of "successfully meets expectations" for many goals, but she received a rating of "requires development" for the goal of providing high quality EAP services.

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JACKSON-NIBBS v. UNITED WAY OF CENTRAL INDIANA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-nibbs-v-united-way-of-central-indiana-insd-2021.