Katherine Merhulik v. Weltman, Weinberg & Reis Co. LPA

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 19, 2022
Docket21-3773
StatusUnpublished

This text of Katherine Merhulik v. Weltman, Weinberg & Reis Co. LPA (Katherine Merhulik v. Weltman, Weinberg & Reis Co. LPA) 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
Katherine Merhulik v. Weltman, Weinberg & Reis Co. LPA, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0203n.06

No. 21-3773

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 19, 2022 DEBORAH S. HUNT, Clerk ) KATHERINE MERHULIK, ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE NORTHERN ) DISTRICT OF OHIO WELTMAN, WEINBERG & REIS CO. LPA, ) Defendant-Appellee. ) OPINION ) )

Before: SILER, CLAY, and MURPHY, Circuit Judges.

CLAY, Circuit Judge. Plaintiff Katherine Merhulik appeals the district court’s order

granting summary judgment for Defendant Weltman, Weinberg & Reis Co. (“Weltman”) in this

action asserting violations of federal and state anti-discrimination and anti-retaliation laws under

the Age Discrimination in Employment Act, 29 U.S.C. § 623(a)(1), (d) (“ADEA”) and Ohio’s

state law corollary, Ohio Rev. Code Ann. §§ 4112.02(I), .14. For the reasons set forth below, this

Court AFFIRMS.

I. BACKGROUND

On July 13, 2009, at the age of fifty-two, Plaintiff Katherine Merhulik, now known as

Katherine Leeds, began employment at Defendant Weltman, a law firm, as a legal collector.

Within a year of employment, Merhulik was transferred from the downtown Cleveland office to

the Brooklyn Heights office. With that office change, the scope of her job duties also shifted; she

began to focus on the Ohio Attorney General’s portfolio, which included complicated student loans No. 21-3773, Merhulik v. Weltman, Weinberg & Reis Co. LPA

and tax collections. Management of this portfolio proved onerous for Merhulik. While Merhulik

sometimes met the monthly collections expectations, measured by calls made and revenue

collected, she more often struggled to meet the departmental quantitative goals.

On February 9, 2010, her supervisor at Weltman issued Plaintiff a documented verbal

warning for unsatisfactory job performance for failure to achieve monthly goals for November

2009, December 2009, and January 2010 and placed her on a performance improvement plan.

Another verbal warning came on June 1, 2011, when Merhulik failed to follow the applicable

procedures required to comply with federal law, which resulted in an unauthorized payment being

deducted from an individual’s bank account. On July 6, 2011, Merhulik received a written warning

for poor performance for failing to meet goals for the prior six months and a low three-month

collections average. Another verbal warning for performance came on June 8, 2012, instructing

Merhulik to increase the percentage of her collections goal for the following month. This Merhulik

failed to do, as she achieved only 75.40% of her collections goal, falling short of the expected

range of 85–90% of debts collected. As a result, Weltman issued a written warning to Plaintiff on

July 3, 2012.

Her annual performance evaluations summarized these shortcomings. In her first written

performance review on February 25, 2010, Merhulik received a rating of two out of a possible five

on the “productivity” and “monthly quotas” categories, which correlated with a rating of “did not

meet the standard.” Her 2010 mid-year evaluation led to placement on a performance

improvement plan. More of the same came in Plaintiff’s July 2011 annual review, in which she

again received a two of five in the productivity category. It noted she “has had challenges with

meeting her goal requirements recently” and that she has struggled with communication and with

“handling high-stress situations[.]” (July 31, 2011 Performance Evaluation, R. 35-3, PageID #

-2- No. 21-3773, Merhulik v. Weltman, Weinberg & Reis Co. LPA

451). Her last annual review as a Weltman collector came in August 2012. In that evaluation,

Merhulik received a rating of two in the “job knowledge, skills & abilities” section because, per

her supervisor, “Kathy struggles to use the knowledge and training that she has been given to

effectively complete her job. She struggles to bring her route current[,] which ultimately affects

her performance.” (Aug. Evaluation, R. 35-3, PageID # 456). Defendant again placed Plaintiff

on a performance improvement plan.

In late 2012, Defendant posted an opening for a position called Quality Assurance Call

Monitor in the Collections Strategy Services Department. Merhulik decided to apply, and, on

November 24, 2012, she assumed that position. Plaintiff characterizes this job change as a

promotion; Defendant points out, however, that the job change occurred because Merhulik applied

to and obtained an open position. Most importantly, for present purposes, once Plaintiff moved

out of the collector position in November 2012, that marked the last time she ever worked as a

collector, whether for Defendant or any other organization. Merhulik’s new role at Weltman

proved more apt for her, and she met or exceeded all job expectations in her 2014 and 2015

performance evaluations.

Plaintiff’s employment at Weltman ended on September 1, 2016, when Merhulik, then age

fifty-nine, had her position eliminated in a company-wide reduction in force. Sixteen of the

twenty-three terminated employees, including Merhulik, were over the age of forty. Plaintiff’s job

duties were distributed to the remaining employees in the department, who were ages forty-four,

forty-nine, and fifty.

On November 2, 2017, Weltman posted a job opening for a collector position listed as Job

Requisition Number 2547 (“First Posting”). Merhulik, then age sixty and no longer employed at

Weltman, applied by submitting a resume and answering pre-screen questions. Thirty-three

-3- No. 21-3773, Merhulik v. Weltman, Weinberg & Reis Co. LPA

applicants responded to the First Posting, but Weltman ultimately withdrew the posting and did

not hire anyone to fill it. However, Weltman interviewed one candidate and extended that person

an offer, but it later rescinded the offer and removed the posting after the candidate failed a

background check.

On January 2, 2018, the firm listed a new posting for a Collections Specialist position

designated Job Requisition Number 2569 (“Second Posting”). “The entry[-]level collector

position is one of the lower-level, higher turnover positions, similar to a clerical position.” (Pl.’s

Resp., R. 41, PageID # 1558). The resume Plaintiff submitted to the First Posting and the Second

Posting showed she had no work experience between her September 2016 separation from

Weltman and her January 2018 application. Plaintiff did not receive a phone interview and was

not selected for the position in the Second Posting. Defendant says that it did not select Merhulik

for a phone interview after determining that her prior work experience at Weltman showed that

she was not a good candidate. Ultimately, Weltman hired a different applicant for the Collections

Specialist position (“chosen candidate”).

Procedural History

On February 27, 2017, Plaintiff filed suit against Defendant in the Cuyahoga County Court

of Common Pleas, alleging that Weltman terminated her based on her age when it included her in

the September 2016 reduction in force. Plaintiff also alleged that Weltman’s reduction in force

had a disparate impact on older employees. The case proceeded through discovery, but Plaintiff

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