Lahmeyer v. Brunswick Corporation

CourtDistrict Court, N.D. Indiana
DecidedMay 14, 2025
Docket1:25-cv-00111
StatusUnknown

This text of Lahmeyer v. Brunswick Corporation (Lahmeyer v. Brunswick Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lahmeyer v. Brunswick Corporation, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

KAYLA L. LAHMEYER ) ) Plaintiff, ) ) v. ) CASE NO.: 1:25-cv-111-HAB ) BRUNSWICK CORPORATION, ) ) Defendant. ) ) )

OPINION AND ORDER

Plaintiff, Kayla Lahmeyer (“Lahmeyer”), sued Defendant, Brunswick Corporation (“Brunswick”), alleging sexual harassment and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000 (“Title VII”). (ECF No. 2). Lahmeyer asserts—among other things— that Brunswick made her employment so hellish that she was forced to resign such that she was constructively discharged. (Id.). Before availing herself to this forum, Lahmeyer had to exhaust her administrative remedies by filing a Charge of Discrimination with the proper agency. Although she filed a charge, she did so weeks before her resignation and thus before her claim for constructive discharge ever existed. Brunswick now moves to dismiss Lahmeyer’s claims for constructive discharge on that basis. (ECF No. 8). That motion is now fully briefed (ECF Nos. 9, 14, 15) and ripe for ruling. I. Standard of Review

Federal Rule of Civil Procedure 12(b)(6) provides for the dismissal of a complaint, or any portion of a complaint, for failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citations and internal quotation marks omitted); see also Ray v. City of Chi., 629 F.3d 660, 662-63 (7th Cir. 2011). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. When analyzing a motion to dismiss a claim under Rule 12(b)(6), the

factual allegations in the complaint must be accepted as true and viewed in the light most favorable to the plaintiff. Brokaw v. Mercer Cnty., 235 F.3d 1000, 1006 (7th Cir. 2000). That said, the Court is not “obliged to accept as true legal conclusions or unsupported conclusions of fact.” Bielanski v. Cty. Of Kane, 550 F.3d 632 (7th Cir. 2008). And “[t]hreadbare recitals of the elements of a cause of action, supported by merely conclusory statements do not suffice.” Iqbal, 556 U.S. at 678. II. Well-Pleaded Facts

On February 21, 2024, Lahmeyer filed a Charge of Discrimination (“Charge”) with the Equal Employment Opportunity Commission (“EEOC”) alleging sex discrimination and retaliation against Brunswick under Title VII. (ECF No. 2-1). After experiencing sexual harassment from a coworker, she took her grievances to Brunswick’s Human Resources Director, Susie Eberle (“Eberle”), and her Supervisor, Leigh Ann Osbourne (“Osbourne”). (Id.). It appears that Eberle and Osbourne dismissed Lahmeyer’s concerns and Eberle responded by giving her a Progressive Discipline form detailing several of Lahmeyer’s disciplinary matters for the first time. (Id.). Pertinent here, Lahmeyer stated, “[Eberle] and [Osbourne] have made i[t] such that Complainant’s work environment is now so hellish and so unreasonable that it is quite apparent to Complainant that she is being set up for discharge.” (Id.). In her Complaint (ECF No. 2), Lahmeyer claims that “the retaliation got so bad and the work environment got so hellish that [she] had no other choice but to resign on or about March 12, 2024, at which time [she] was constructively discharged.” (Id. ¶ 3). Lahmeyer filed no other charges of discrimination—nor did she amend the Charge from February 21, 2024—before suing in this forum. III. Discussion

Title VII makes it unlawful for an employer “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions or privileges of employment, because of such individual’s…sex[.]” 42 U.S.C. § 2000e-2(a)(1). Title VII also prohibits employers from retaliating against an employee who “has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing.” 42 U.S.C. § 2000e-3(a). Whether asserting claims for discrimination, retaliation, or constructive discharge, “[b]efore bringing a Title VII claim, a plaintiff must first exhaust h[er] administrative remedies by filing charges with the EEOC and receiving a right to sue letter.” Chaidez v. Ford Motor Co., 937 F.3d 998, 1004 (7th Cir. 2019).

“[T]he scope of the complaints brought before the [EEOC] limits the scope of subsequent civil proceedings in federal court; in other words, plaintiffs may pursue only those claims that could reasonably be expected to grow out of the administrative charges.” Reynolds v. Tangherlini, 737 F.3d 1093, 1099-1100 (7th Cir. 2013). The purpose of the exhaustion requirement is two-fold: it gives the EEOC and the employer an opportunity to settle the dispute, and it puts the employer on notice of any charges against it. Rush v. McDonald's Corp., 966 F.2d 1104, 1110 (7th Cir. 1992). With this backdrop, Brunswick argues that Lahmeyer’s claims based on constructive discharge must be dismissed because she resigned several weeks after she filed the Charge. “A claim of constructive discharge…has two basic elements[:] [a] plaintiff must prove first that [s]he was discriminated against by h[er] employer to the point where a reasonable person in h[er] position would have felt compelled to resign.” Green v. Brennan, 578 U.S. 547, 555 (2016). But she “must also show that [s]he actually resigned.” Id. Indeed, a constructive discharge claim “does not exist until the employee resigns.” Id. at 562.1 Lahmeyer never filed another charge or amended

the Charge with the EEOC. This Supreme Court precedent, Brunswick argues, thus requires dismissal of her constructive discharge claims. Lahmeyer, in response, did not address Green despite that decision forming a large portion of Brunswick’s argument. Instead, she argues that “a Title VII plaintiff need not allege in an EEOC charge each and every fact that combines to form the basis of each claim in her complaint.” Cheek v. Western and Southern Life Ins., 31 F.3d 497, 500 (7th Cir. 1994). And Lahmeyer posits that her claim must survive if her constructive discharge claims “are like or reasonably related to the allegations of the charge and growing out of such allegations.” Id. That determination requires the Court to examine whether the Charge “g[a]ve notice to [Brunswick] of the [constructive discharge]

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ray v. City of Chicago
629 F.3d 660 (Seventh Circuit, 2011)
C.A. Brokaw v. Mercer County, James Brokaw, Weir Brokaw
235 F.3d 1000 (Seventh Circuit, 2000)
Bielanski v. County of Kane
550 F.3d 632 (Seventh Circuit, 2008)
Teal v. Potter
559 F.3d 687 (Seventh Circuit, 2009)
James Reynolds v. Daniel M. Tangherlini
737 F.3d 1093 (Seventh Circuit, 2013)
Green v. Brennan
578 U.S. 547 (Supreme Court, 2016)
Martin Chaidez v. Ford Motor Company
937 F.3d 998 (Seventh Circuit, 2019)
Smith v. Farmstand
909 F. Supp. 2d 1001 (N.D. Illinois, 2012)

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Bluebook (online)
Lahmeyer v. Brunswick Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lahmeyer-v-brunswick-corporation-innd-2025.