Kelly McLaughlin v. Fifth Third Bank, Inc.

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 24, 2019
Docket18-5712
StatusUnpublished

This text of Kelly McLaughlin v. Fifth Third Bank, Inc. (Kelly McLaughlin v. Fifth Third Bank, Inc.) 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
Kelly McLaughlin v. Fifth Third Bank, Inc., (6th Cir. 2019).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 19a0273n.06

No. 18-5712

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 24, 2019 KELLY MCLAUGHLIN and JANET RANIERO, ) DEBORAH S. HUNT, Clerk ) Plaintiffs-Appellants, ) ) v. ) ON APPEAL FROM THE ) UNITED STATES DISTRICT FIFTH THIRD BANK, INC., ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY Defendant-Appellee. ) )

BEFORE: BOGGS, BATCHELDER, and STRANCH, Circuit Judges.

BOGGS, Circuit Judge. Like many banks, Appellee Fifth Third Bank, Inc. has a “dual-

control policy” to govern entry to its cash vaults. To open a cash vault, two different employees

must turn two different keys; both must remain present during the transaction; and then both must

sign a log book to record their participation. In January 2013, Fifth Third learned that employees

at its busy Newport, Kentucky location were habitually violating this policy. Fifth Third opened

an internal investigation and reviewed security video to identify any possibly offending employees.

Appellants Kelly McLaughlin and Janet Raniero were two of the employees seen on the security

video, and both admitted to investigators that they had violated bank policy.

Fifth Third fired McLaughlin, Raniero, and another female employee for violating of the

dual-control policy. McLaughlin and Raniero claim that three male employees—Randall Dreyer,

Blake Hoover, and Joseph Durrett—also violated the dual-control policy but were not fired by

Fifth Third and instead received performance counseling. Two of the three male employees were No. 17-5712, McLaughlin v. Fifth Third Bank

not seen on video violating the policy and did not admit to violating the policy. The third, Dreyer,

was seen on video and admitted to violating the dual-control policy, but Fifth Third did not fire

him due to “mitigating circumstances,” namely that a superior had bullied him into the violation,

he complained about being forced to do it, and he refused to do it again when asked by

McLaughlin, who was not his superior and described him as a “by-the-book guy.” McLaughlin

and Raniero argue that Fifth Third should have either fired the men as it did the women or ordered

the women to receive performance counseling as it did the men and that failure to treat men and

women equally shows that Fifth Third was using the dual-control policy violations as a pretext for

engaging in sex discrimination.

McLaughlin and Raniero sued Fifth Third for sex discrimination under Title VII of the

Civil Rights Act of 1964, and Raniero also brought a claim for age discrimination under the Age

Discrimination in Employment Act. The district court granted Fifth Third’s summary-judgment

motion and plaintiffs appealed. For the reasons set forth below, we affirm.

I. Standard of Review

On appeal, entry of summary judgment is reviewed de novo. Simpson v. Ernst & Young,

100 F.3d 436, 440 (6th Cir. 1996). Summary judgment is proper 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). Once the movant meets the initial burden, the opposing party must set

forth specific facts showing that there is a genuine issue for trial. Fed. R. Civ. P. 56(e). All

evidence must be considered in the light most favorable to the non-moving party. Anderson v.

Liberty Lobby, Inc., 477 U.S. 242, 255 (1986).

To establish a Title VII employment-discrimination claim, a party must “present direct

evidence of discrimination or introduce circumstantial evidence that would allow an inference of

-2- No. 17-5712, McLaughlin v. Fifth Third Bank

discriminatory treatment.” Carter v. Univ. of Toledo, 349 F.3d 269, 272 (6th Cir. 2003).

McLaughlin’s and Raniero’s claims are based on circumstantial evidence and as such must be

evaluated under the burden-shifting framework of McDonnell Douglas Corp. v. Green, 411 U.S.

792 (1973). McDonnell Douglas requires that McLaughlin and Raniero present a prima facie case

of discrimination, which creates a rebuttable presumption that discrimination occurred and shifts

the burden to Fifth Third to articulate a legitimate non-discriminatory reason for taking the

challenged employment action. The district court held that there was no genuine issue of material

fact that violation of Fifth Third’s cash-vault dual-control policy was a legitimate non-

discriminatory reason for Fifth Third to fire McLaughlin and Raniero. With Fifth Third satisfying

its burden, McLaughlin and Raniero must prove that proffered reason was actually a pretext to

hide unlawful activity. Carter, 349 F.3d at 273.

II.

There are three ways to show pretext: 1) the proffered reason had no basis in fact; 2) the

proffered reason did not actually motivate the employer’s actions; or 3) the proffered reason was

insufficient to motivate the employer’s action. Chen v. Dow Chem. Co., 580 F.3d 394, 400 (6th

Cir. 2009).

To carry her burden in opposing summary judgment, [plaintiff] must produce sufficient evidence from which a jury could reasonably reject [defendant’s] explanation of why it fired her…When an employer reasonably and honestly relies on particularized facts in making an employment decision, it is entitled to summary judgment on pretext even if its conclusion is later shown to be mistaken, foolish, trivial, or baseless.

Chen, 580 F.3d at 400-01 (emphasis added). Under the “honest-belief” doctrine, a pretext

determination does not hinge on whether policy violations occurred, but whether Fifth Third

reasonably and honestly believed in its nondiscriminatory reason for treating women differently

than similarly-situated men. “[T]he key inquiry is whether the employer made a reasonably

informed and considered decision before taking an adverse employment action.” Smith v. Chrysler -3- No. 17-5712, McLaughlin v. Fifth Third Bank

Corp., 155 F.3d 799, 807 (6th Cir. 1998). The employee “must allege more than a dispute over

the facts upon which his discharge was based.” Braithwaite v. Timken Co., 258 F.3d 488, 494 (6th

Cir. 2001). An employee can overcome the honest-belief doctrine

[w]hen the employee is able to produce sufficient evidence to establish that the employer failed to make a reasonably informed and considered decision before taking its adverse employment action, thereby making its decisional process ‘unworthy of credence,’ then any reliance placed by the employer in such a process cannot be said to be honestly held.

Wright v. Murray Guard, Inc., 455 F.3d 702, 708 (6th Cir. 2006) (citation omitted).

On appeal, McLaughlin and Raniero argue that the three male employees violated the dual-

control policy, citing witness interviews, affidavits, and depositions.

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
P. Larue Simpson v. Ernst & Young
100 F.3d 436 (Sixth Circuit, 1996)
James P. Smith v. Chrysler Corporation
155 F.3d 799 (Sixth Circuit, 1998)
Harold F. Braithwaite v. The Timken Company
258 F.3d 488 (Sixth Circuit, 2001)
Carolyn Carter v. University of Toledo
349 F.3d 269 (Sixth Circuit, 2003)
Cornelius Wright v. Murray Guard, Inc.
455 F.3d 702 (Sixth Circuit, 2006)
Chen v. Dow Chemical Co.
580 F.3d 394 (Sixth Circuit, 2009)

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