Schnapp v. FCA US LLC

CourtDistrict Court, N.D. Ohio
DecidedSeptember 8, 2022
Docket3:20-cv-00067
StatusUnknown

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

Bluebook
Schnapp v. FCA US LLC, (N.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

Gerald Schnapp, Case No. 3:20-cv-67

Plaintiff,

v. MEMORANDUM OPINION AND ORDER

FCA US LLC,

Defendant.

I. INTRODUCTION

On January 13, 2020, Plaintiff Gerald Schnapp filed a complaint against his employer Defendant FCA US LLC, alleging an age discrimination claim under the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621 et seq. (Doc. No. 1). On July 16, 2021, FCA filed a motion for summary judgment, (Doc. No. 19), which has been fully briefed. (See Doc. Nos. 23 & 24). For the reasons stated below, I grant FCA’s motion for summary judgment. II. BACKGROUND Schnapp was born November 19, 1966, and was over the age of 40 at all times relevant to this litigation. (Doc. No. 19-2 at 6). Schnapp has been employed by FCA since May 1994; and, since 1998, has held the position of Machine Repairman at FCA’s Toledo Machining Plant. (Id. at 17, 19). Schnapp has complained of promotion denials dating back as far as 2005 for numerous positions. (See, e.g., id. at 20-21, 78-80, 110-17; Doc. No. 23 at 2-3, 6). He believes he was denied many of these positions because he was overqualified. (Id. at 28-29); (see id. at 58) (“The previous times I submitted resumes . . . I wrote a lot about what I did. And after a while, I thought it was hurting me because I was showing too much experience.”). Schnapp testified his age discrimination claim specifically relates to promotion denials. (Id. at 23). On July 5, 2018, Schnapp applied for an Industrial Engineer position at the Toledo Assembly Complex. (Id. at 53). The job posting listed both basic and preferred qualifications. (Doc. No. 19-3). Schnapp submitted an application which listed his Bachelor’s and Master’s degrees in Industrial Tech, and stated from February 1998 through December 2013 his job duties were “PM

Machinery.” (Doc. No. 19-4). The application contained no other information related to Schnapp’s work history, skills, or relevant experience. (Id. at 2). Schnapp does not know if his professional resume was attached to this application. (Doc. No. 19-2 at 71). Schnapp was not interviewed for, nor offered, the Industrial Engineer position. (Id. at 59). He testified he had no reason to believe that he was not offered the position because of his age. (Id. at 60-61). FCA ultimately did not hire anyone for this position. (Id. at 61). On July 24, 2018, Schnapp applied for a Tool & Process Engineer position at the Toledo Machining Plant. (Doc. No. 19-5). Again, the job posting listed both basic and preferred qualifications. (Doc. No. 19-6). For example, the basic qualifications required a Bachelor’s degree and proficiencies in MS Office, AutoCAD, and CNC programming. (Id.). The preferred qualification requested specific engineering degrees. (Id.). Schnapp submitted the same application as before, which listed only his Bachelor’s and Master’s degrees and his job duties as “PM Machinery” from 1998 through 2013. (Doc. No. 19-7). The application contained no other

information related to Schnapp’s work history, skills, or relevant experience. (Id. at 2). Schnapp does not know if his professional resume was attached to this application. (Doc. No. 19-2 at 71). Engineering Supervisor and Facilities Manager Douglas Duke1 was responsible for the hiring decision for this position. (Doc. No. 19-2 at 71; Doc. No. 20 at 1-2). Duke stated several reasons why he did not interview Schnapp for the position. First, Schnapp did not possess a degree in Mechanical Engineering, Mechanical Engineering Technology, or Electrical Engineering. (Doc. No. 20 at 2; see also Doc. Nos. 19-6 & 19-7). Pursuant to the job posting, this was a preferred qualification and all the applicants selected for an interview possessed one of these degrees. (Doc.

No. 19-6; Doc. No. 20 at 2). Second, Schnapp’s application did not identify any knowledge of, or experience with, AutoCAD or CNC programming. (Doc. No. 20 at 2; see also Doc. Nos. 19-6 & 19- 7). Third, Schnapp’s application “failed to demonstrate how his previous work experience satisfied any of the position requirements.” (Id.). Fourth, Duke had reservations about Schnapp’s behavior and apparent lack of motivation. (Doc. No. 20 at 2-3). These reservations arose from separate incidents. Duke’s concern regarding Schnapp’s behavior involved a complaint by a co-worker, Jack Rubinsaal, who claimed Schnapp intentionally disorganized his toolbox and filled his toolbox lock with Loctite. (Id.). Both Rubinsaal and Schnapp’s supervisor reported this incident to Duke. (Id.). Resolution of the incident required union involvement. (Id.). Schnapp denied any involvement in the incident and was not disciplined. (Doc. No. 19-2 at 85-86). Duke was also concerned about Schnapp’s lack of self-direction. (Doc. No. 20 at 3). On multiple occasions, Duke observed Schnapp “sitting down during his shift waiting to be directed to

perform work.” (Id.). This was notable to Duke because Schnapp had the ability to assign his own work by accessing the “Total Maintenance System” to identify available, planned maintenance

1 Schnapp testified Duke was approximately his own age and indeed, Duke was born in 1965. (Doc. No. 19-2 at 60; Doc. No. 20 at 1). assignments, but he did not. (Id.). Self-direction is one of the basic qualifications for the Tool & Process Engineer position. (Doc. No. 19-6). Schnapp was not interviewed for, nor offered the position of, Tool & Process Engineer. (Doc. Nos. 19-10 & 20). Instead, FCA hired Alex Gonzalez2 to fill the position on January 22, 2019. (Doc. No. 19-11). Gonzalez was a recent graduate with a Bachelor’s in Engineering Technology. (Doc. No. 19-12 at 2, 4). His resume describes coursework and previous job experience with both

CNC and AutoCAD. (Id. at 4). Further, he had interned at the Toledo Machining Plant as a Maintenance Supervisor where he earned positive feedback from his supervisor, had experience in FCA’s WCM3 methodologies, and Duke was familiar with his work performance and work ethic. (Doc. No. 20 at 2). Duke recommended Gonzalez be hired based on this education and work history. (Id. at 3). With regard to Gonzalez’s hiring and his failure to earn an interview, Schnapp testified: When they hire someone who’s fresh out of college, the same college I went to, with less grades than me, and I have a master’s degree on top of mine, I have nothing else to infer but it’s age discrimination.

(Doc. No. 19-2 at 75). He also testified he believed Duke’s behavioral and motivational concerns were after-the-fact excuses to cover up the age discrimination. (Id. at 86). On October 16, 2018, Schnapp filed a charge with the Ohio Civil Rights Commission asserting an age discrimination claim resulting from his denial of the two above-described promotions. (Doc. No. 1-1). Schnapp was issued a “Right to Sue” notice on October 17, 2019, (Doc. No. 1-2), and he timely filed his complaint on January 13, 2020. (Doc. No. 1).

2 Gonzalez’s exact age at the time of his hiring is not identified, but neither party disputes he is younger than Schnapp and not in a protected age class.

3 WCM stands for World Class Manufacturing. This is a program adopted by FCA that promotes lean manufacturing and a continuous improvement philosophy with a goal towards zero waste. (Doc. No. 19 at 9 n.1). III. STANDARD Summary judgment is appropriate where “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).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
St. Mary's Honor Center v. Hicks
509 U.S. 502 (Supreme Court, 1993)
Gross v. FBL Financial Services, Inc.
557 U.S. 167 (Supreme Court, 2009)
Provenzano v. LCI Holdings, Inc.
663 F.3d 806 (Sixth Circuit, 2011)
Ruby Harris v. General Motors Corporation
201 F.3d 800 (Sixth Circuit, 2000)
Harold F. Braithwaite v. The Timken Company
258 F.3d 488 (Sixth Circuit, 2001)
Saeid B. Amini v. Oberlin College
259 F.3d 493 (Sixth Circuit, 2001)
Donald G. Wexler v. White's Fine Furniture, Inc.
317 F.3d 564 (Sixth Circuit, 2003)
Allen v. Highlands Hospital Corp.
545 F.3d 387 (Sixth Circuit, 2008)
Chen v. Dow Chemical Co.
580 F.3d 394 (Sixth Circuit, 2009)
Geiger v. Tower Automotive
579 F.3d 614 (Sixth Circuit, 2009)
Cline v. Catholic Diocese of Toledo
206 F.3d 651 (Sixth Circuit, 2000)
Hughes v. General Motors Corp.
212 F. App'x 497 (Sixth Circuit, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
Schnapp v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schnapp-v-fca-us-llc-ohnd-2022.