Tammy Ludwig v. St. Joseph County, et al.

CourtDistrict Court, N.D. Indiana
DecidedMay 4, 2026
Docket3:24-cv-00800
StatusUnknown

This text of Tammy Ludwig v. St. Joseph County, et al. (Tammy Ludwig v. St. Joseph County, et al.) 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
Tammy Ludwig v. St. Joseph County, et al., (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

TAMMY LUDWIG,

Plaintiff,

v. Case No. 3:24-CV-800-CCB

ST JOSEPH COUNTY, et al.,

Defendants.

OPINION AND ORDER Plaintiff Tammy Ludwig sued Defendants St. Joseph County and St. Joseph County Public Safety Communications Consortium under the Age Discrimination Employment Act, 29 U.S.C. § 621 et. seq. (ADEA).1 The Court now rules on Defendants’ motion for summary judgment. (ECF 19). BACKGROUND The following facts are undisputed unless otherwise noted.2 This case arises from Plaintiff Tammy Ludwig’s termination from her employment with Defendant St. Joseph County Public Safety Communications Consortium (“Consortium”). Ms. Ludwig was first hired by St. Joseph County as a police dispatcher in January 2005 and was then transferred to an emergency dispatcher position within the Consortium. (ECF 21 ¶ 1–2).

1 Plaintiff also alleged gender discrimination under Title VII, 42 U.S.C. § 2000e et seq. However, in her Response brief, she has withdrawn that claim. (ECF 30 at 16). Thus, summary judgment is automatically granted on it. See Williams v. Lovchik, 830 F. Supp. 2d 604, 614 (S.D. Ind. 2011). 2 To dispute a fact, the party opposing summary judgment must identify the fact as disputed and cite to evidence which raises a genuine dispute. N.D. Ind. L. R. 56-1(b)(2)(C); Fed. R. Civ. P. 56; Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). Thus, a fact is undisputed if the party either noted it as such, or cited no evidence which raised a genuine dispute. A Collective Bargaining Agreement (“CBA”) outlined Ms. Ludwig’s employment terms and conditions. (ECF 21 ¶ 5). The CBA provided for the employment discipline process,

outlining three offense categories: Group I, Group II, and Group III. (ECF 21 ¶ 10). A Group I offense is defined as “tardiness or failure to report for duty within a reasonable amount of time.” A Group II offense includes excessive absenteeism or failure to report for a mandated on-call shift. (ECF 31 ¶¶ 11, 13). Group III offenses include “dishonesty or any dishonest action” and “insubordination by refusing to perform assigned work or to comply with written or verbal instruction of supervisors.”

(ECF 31 ¶ 15). While specific progressive disciplinary steps are required for Group I and II offenses, (e.g., verbal warning, written warning, written reprimand, suspension, etc.), “the employer reserves the right to terminate an employee for [a Group III] offense without proceeding through progressive discipline.” (ECF 31 ¶¶ 8–15). This case revolves around two Group III offenses that are the alleged grounds for Ms. Ludwig’s

termination. 1. First Discipline Event

On June 15, 2023, Deputy Director Nicole Ingle sent an email to all dispatchers at the Consortium, informing them that their on-call days had been assigned. (ECF 31 ¶ 28). In the email, she instructed each dispatcher to check their assigned dates and contact her with any questions. (Id.). Plaintiff had previously been granted vacation

time during her listed on-call shift on August 5, 2023. (ECF 31 ¶ 32). However, she did not contact Ingle to inquire about this conflict until July 31. (ECF 31 ¶ 31). On July 31, 2023, Plaintiff emailed Ingle asking why she was listed as on-call for August 5 when she was on vacation time during that period. (ECF 31 ¶ 32). Ingle

immediately responded and informed Plaintiff that she should have communicated this conflict earlier. (ECF 31 ¶ 33). Ingle also notified Plaintiff that she needed to find a replacement for the August 5 shift. (ECF 31 ¶ 34). Plaintiff did not attempt to find a replacement. (ECF 31 ¶ 37). When she was contacted on August 4 and told she would need to work the next day, she stated that she was unable to do so, as she was on vacation time. (ECF 31 ¶ 39). Plaintiff did not

attend the on-call shift on August 5, 2023, and her shift was covered by another employee. (ECF 31 at 15–16). After this, Ingle prepared a Group II Notice of Unsatisfactory Performance offense designation. (ECF 31 at 17). However, after Deputy Director Nick Brovold became aware of Plaintiff’s actions, he prepared a Group III insubordination charge.

(ECF 31 ¶ 43). Plaintiff was given a pre-disciplinary hearing per the Group III procedures on August 7, 2023. (ECF 31 ¶ 44). After the hearing, Brovold concluded that Plaintiff had engaged in insubordination. (ECF 19-24 at 3). However, he testified that Plaintiff would receive only a written reprimand because this was her first Group III offense (“first Group III

offense”). (Id.). The parties dispute whether the CBA’s terms required Plaintiff to notify Defendants of her vacation time conflict when the schedule was originally sent out on June 15, and also dispute whether Plaintiff was required to work or find a shift replacement for the on-call shift on August 5, 2023 when she had previously been scheduled for vacation time. (ECF 20 at 11; 30 at 8).

2. Second Discipline Event On November 12, 2023, Plaintiff received a jury duty notice for December 12,

2023. (ECF 31 ¶ 64). Plaintiff notified a supervisor, who edited the shift schedule on November 12, 2023. Later, her jury duty was cancelled. (ECF 31 ¶ 65). Plaintiff informed her supervisor of the cancellation. (ECF 31 ¶ 66). However, at some time before December 12, 2023, Plaintiff realized that she was not listed on any of the shifts for that day, even after she had reported her jury duty

cancellation. (ECF 31 ¶ 67). In fact, an employee had mistakenly modified the schedule by performing a “hard delete” that completely removed Plaintiff from the shifts for that day, rather than marking her as excused for a specific shift. (ECF 31 ¶ 67). This errant change was not reflected in the “master list” that only Plaintiff’s supervisors had access to. On that list, Plaintiff was still scheduled to work on December 12, 2023. Defendants

allege that Plaintiff was dishonest in not reaching out regarding her scheduling and must have known that there was an error when she saw that she had been completely removed from the schedule for that day. (ECF 31 ¶ 67). Due to their alleged dishonesty finding, Defendants determined that Plaintiff had committed another Group III offense and terminated her (“second Group III Offense”). (ECF 31 ¶ 91).3

3 The parties also debate the number and nature of additional Group I and II offenses that Plaintiff received. But neither party argues that these offenses were the basis for Plaintiffs’ termination. Thus, the Court does not address them here. See Specht v. Google Inc., 758 F. Supp. 2d 570, 577 (N.D. Ill. 2010) (“The Court should not consider disputes over irrelevant or unnecessary facts.”). Plaintiff denies this inference, alleging that she had no access to the master schedule and had never previously been excused for jury duty and thus had no sense of

what proper procedures were. (ECF 31 at 26). She also alleges that she was deterred from asking follow-up questions by Defendants’ hostile response to her previous schedule clarification query on July 31. (ECF 31 at 33). STANDARD Summary judgment is appropriate when “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).

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