Rabenhorst v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security

CourtDistrict Court, N.D. Illinois
DecidedJanuary 22, 2024
Docket1:21-cv-03620
StatusUnknown

This text of Rabenhorst v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security (Rabenhorst v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rabenhorst v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security, (N.D. Ill. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

KARL RABENHORST,

Plaintiff, No. 21 CV 3620 v. Judge Manish S. Shah ALEJANDRO MAYORKAS, Secretary, United States Department of Homeland Security,

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Karl Rabenhorst worked for the Federal Emergency Management Agency for approximately 14 years as a technical hazard specialist. During his time there, Rabenhorst’s employer reprimanded or disciplined him repeatedly. Believing that he was treated differently than his younger, women colleagues, Rabenhorst filed an EEO complaint with FEMA alleging sex and age discrimination and retaliation. After FEMA found no evidence of discrimination or retaliation, Rabenhorst brought this case alleging the same. Defendant moves for summary judgment. I. Legal Standard Summary judgment is warranted if there are no genuine disputes of material fact and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). “‘Material facts’ are facts that ‘might affect the outcome of the suit,’ and a dispute as to those facts is ‘genuine’ if ‘the evidence is such that a reasonable jury could return a verdict for the nonmoving party.’” Hunter v. Museke, 73 F.4th 561, 565 (7th Cir. 2023) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). A court need consider only the cited materials, but it may consider other materials in the record. Fed. R. Civ. P. 56(c)(3). The non-moving party is given “the benefit of conflicting evidence and any favorable inferences that might be reasonably drawn

from the evidence.” Runkel v. City of Springfield, 51 F.4th 736, 741 (7th Cir. 2022). II. Local Rule 56.1 and Evidentiary Issues The evidence submitted through Local Rule 56.1 statements of fact must be admissible at trial, except that affidavits or depositions may be accepted in lieu of live testimony. See Fed. R. Civ. P. 56(c); Eisenstadt v. Centel Corp., 113 F.3d 738, 742 (7th Cir. 1997). Testimony presented through affidavits or depositions must be admissible, and admissibility usually requires the declarant or affiant’s personal knowledge. See

Fed. R. Civ. P. 56(c)(4); Fed. R. Evid. 602. “Inasmuch as summary judgment procedure lacks the safeguard of cross-examination of an affiant, it is important that it be shown that he is competent to testify to the matters therein stated and that the facts to which he swears are admissible under the rules of evidence.” Am. Securit Co. v. Hamilton Glass Co., 254 F.2d 889, 893 (7th Cir. 1958). Rabenhorst submitted a declaration in support of his Local Rule 56.1

statement of additional facts. [46-22].1 Portions of the declaration assert facts without a proper foundation or basis to determine whether Rabenhorst has personal knowledge of the facts. For example, Rabenhorst asserts that in 2012, FEMA leadership relaxed evaluation criteria enforcement. [46-22] ¶ 6. But he provides no

1 Bracketed numbers refer to entries on the district court docket. Referenced page numbers are taken from the CM/ECF header placed at the top of filings. When a document has numbered paragraphs, I cite to the paragraph, for example [1] ¶ 1. foundation for how he knows that fact. Without knowing the source of his knowledge, it is impossible to know whether the testimony is admissible. See Packer v. Trs. of Ind. Univ. Sch. of Med., 800 F.3d 843, 850 (7th Cir. 2015) (rejecting facts asserted in

affidavit when the affidavit did not provide foundation for affiant’s personal knowledge of those facts). For that reason, portions of ¶¶ 6, 8–13, 23–27, 29, and 32 of Rabenhorst’s statement of additional facts are struck. III. Facts Karl Rabenhorst is a white man over 40 years of age who was employed by the Federal Emergency Management Agency of the defendant United States Department of Homeland Security. [44] ¶ 1.2 He began his employment as a technical hazard

specialist in September 2009; before then, Rabenhorst had been in the Navy for 28 years. Id. At FEMA, Rabenhorst was originally assigned to work with state officials

2 The facts are largely taken from Rabenhorst’s response to defendant’s Local Rule 56.1 statement, [44], and defendant’s response to Rabenhorst’s 56.1 statement of additional facts, [50], where both the asserted fact and the opposing party’s response are set forth in one document. Any fact not properly controverted is admitted. N.D. Ill. Local R. 56.1(e)(3); see Cracco v. Vitran Exp., Inc., 559 F.3d 625, 632 (7th Cir. 2009). I disregard all immaterial facts. I ignore additional facts included in responses that do not controvert the asserted fact. See [44] ¶¶ 1–5, 7, 9–11, 15, 18, 23, 26–31, 35–36, 38–39, 42, 44, 46; [50] ¶¶ 4, 12, 21, 24, 33, 35. I also ignore all facts included in statements or responses that are not supported by the parties’ cited evidence. N.D. Ill. Local R. 56.1(d)(2), (e)(3); see [50] ¶¶ 12, 13, 21, 24–26, 33. Defendant’s objection to Rabenhorst’s inclusion of a newspaper article as inadmissible hearsay is sustained. [50] ¶ 20. While newspaper articles are self-authenticating, Fed. R. Evid. 902(6), they are inadmissible hearsay when they are offered for the truth of the matters asserted therein, see Fed. R. Evid. 801(c); Chi. Firefighters Local 2 v. City of Chicago, 249 F.3d 649, 654 (7th Cir. 2001). Rabenhorst makes no argument that he is offering the article for any other purpose. Where the parties dispute facts and both rely on admissible evidence, I set forth both sides’ facts. in Wisconsin, Michigan, and Ohio to develop and review plans for emergency preparedness. [44] ¶ 2. In May 2014, Sean O’Leary was reassigned to be the Tech Hazards Branch

Chief. [50] ¶ 7. Rabenhorst asserts that O’Leary began waiving evaluation criteria, and that Rabenhorst repeatedly counseled O’Leary regarding regulatory requirements and violations. [50] ¶¶ 4, 8. In response, Rabenhorst asserts he was reprimanded for alleged interference and insubordination. Id. In March 2016, Rabenhorst filed a whistleblower complaint with the DHS Office of the Inspector General, [50] ¶ 12, and multiple union grievances, [44] ¶ 23.

Rabenhorst was twice reprimanded for inappropriate interactions with state officials. In April 2016, Rabenhorst was officially reprimanded by a FEMA supervisor for failing to follow the supervisory chain of command when he emailed the Michigan state attorney general to argue about the interpretation of a Michigan state law without FEMA authorization. [44] ¶ 3.

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Rabenhorst v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rabenhorst-v-alejandro-n-mayorkas-secretary-us-department-of-homeland-ilnd-2024.