Whitney v. J.M. Smucker Co.

2025 Ohio 2141
CourtOhio Court of Appeals
DecidedJune 18, 2025
Docket30713, 30714
StatusPublished

This text of 2025 Ohio 2141 (Whitney v. J.M. Smucker Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whitney v. J.M. Smucker Co., 2025 Ohio 2141 (Ohio Ct. App. 2025).

Opinion

[Cite as Whitney v. J.M. Smucker Co., 2025-Ohio-2141.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

JENNIFER WHITNEY C.A. Nos. 30713 30714 Appellant

v. APPEAL FROM JUDGMENT J.M. SMUCKER COMPANY, et al. ENTERED IN THE COURT OF COMMON PLEAS Appellees COUNTY OF SUMMIT, OHIO CASE No. CV-2020-11-3164

DECISION AND JOURNAL ENTRY

Dated: June 18, 2025

HENSAL, Judge.

{¶1} Jennifer Whitney appeals an order of the Summit County Court of Common Pleas

that granted summary judgment to the J.M. Smucker Company (“JMS”) on her retaliation claim

and an order that placed its decision under seal. For the following reasons, this Court affirms.

I.

{¶2} Ms. Whitney worked as an in-house attorney for JMS on employment law issues

and eventually became vice president of employee relations. In August 2019, an employee who

had been terminated from the company’s information services (IS) department sued the company

for sex discrimination. JMS hired outside counsel to defend the lawsuit. One of counsel’s requests

was for the employee relations department to prepare a summary of all the employees who had left

the IS department over the past couple of years, which it did.

{¶3} In June 2020, the spouse of a former IS employee sent JMS a letter, alleging there

was discrimination occurring within the IS department. JMS hired different outside counsel to 2

investigate the allegation. As outside counsel for the investigation began to request documents,

Ms. Whitney expressed concern about producing documents associated with the lawsuit because

she was concerned about waiving attorney-client privilege. Following company meetings, she

believed there was consensus that outside counsel for the lawsuit should control the release of

those documents, and so she did not provide the IS summary to outside counsel for the

investigation. A search of employee email accounts that was performed by a JMS paralegal,

however, uncovered the IS summary and it was provided to outside counsel for the investigation.

That counsel later questioned Ms. Whitney about why she had not produced the IS summary in

response to its document requests.

{¶4} Ms. Whitney, meanwhile, raised concerns about the tactics JMS’s compliance

department used to perform its investigations. An investigation into her concerns was performed

by JMS’s chief executive officer (“CEO”) and chief financial officer (“CFO”), who interviewed

Ms. Whitney and several other employees.

{¶5} Both outside counsel’s investigation into IS and the CEO’s and CFO’s investigation

into the compliance department concluded around the same time. Based on the investigation he

and the CFO did into the compliance department issues, JMS’s CEO initially determined that there

was no reason to terminate Ms. Whitney, but he did fire the head of the compliance department.

After receiving outside counsel for the investigation’s assessment that Ms. Whitney was not

justified in withholding the IS summary and that there were no attorney-client privilege concerns

that would have prevented it from being disclosed, as well as some additional information from

JMS’s chief legal officer, however, the CEO decided to terminate Ms. Whitney. His decision was

challenged by others within the company, but he proceeded with it, in part to ensure that the chief

legal officer would not resign. 3

{¶6} The CEO gave three reasons for Ms. Whitney’s termination. First, he wrote that

the employee relations department was going to be reorganized and her position would be

eliminated. Second, he wrote that Ms. Whitney had performance-related issues. Third, he wrote

that Ms. Whitney exercised poor judgment when she did not consult with the chief legal officer

about whether to release documents to outside counsel for the investigation.

{¶7} Ms. Whitney filed a complaint against JMS, alleging retaliation in violation of Ohio

Revised Code Section 4112.02. She alleged she had been terminated by opposing conduct that

she reasonably believed was in violation of the company’s anti-discrimination policies and for her

participation in investigations into allegations of unlawful employment practices. The trial court

granted summary judgment to JMS, however, concluding that there was no direct or circumstantial

evidence of unlawful retaliation. Regarding an allegation by Ms. Whitney that the chief legal

officer, who also oversaw the compliance department, wanted her terminated, the court concluded

that there was no evidence that the chief legal officer knew Ms. Whitney had accused her of

engaging in unlawful discriminatory practices or that the chief legal officer’s disclosure of

unfavorable information about Ms. Whitney was the but-for cause of Ms. Whitney’s termination.

The court also ordered its decision to be filed under seal. Ms. Whitney has appealed, assigning

five errors.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED BY OVERLOOKING, WEIGHING AND/OR FAILING TO CREDIT EVIDENCE IN CONCLUDING THAT THERE WAS NO DIRECT EVIDENCE OF RETALIATION. 4

{¶8} In her first assignment of error, Ms. Whitney argues that the trial court incorrectly

granted summary judgment to JMS because it overlooked evidence of direct retaliation by the

company. Under Rule 56(C), summary judgment is appropriate if:

[n]o genuine issue as to any material fact remains to be litigated; (2) the moving party is entitled to judgment as a matter of law; and (3) it appears from the evidence that reasonable minds can come to but one conclusion, and viewing such evidence most strongly in favor of the party against whom the motion for summary judgment is made, that conclusion is adverse to that party.

Temple v. Wean United, Inc., 50 Ohio St.2d 317, 327 (1977). To succeed on a motion for summary

judgment, the party moving for summary judgment must first be able to point to evidentiary

materials that demonstrate there is no genuine issue as to any material fact, and that it is entitled

to judgment as a matter of law. Dresher v. Burt, 75 Ohio St.3d 280, 292 (1996). If the movant

satisfies this burden, the nonmoving party “must set forth specific facts showing that there is a

genuine issue for trial.” Id. at 293, quoting Civ.R. 56(E). This Court reviews an award of summary

judgment de novo. Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105 (1996). This Court will

affirm if there is reason to grant summary judgment, even if it does not agree with the trial court’s

rationale. Cosner v. Babcock & Wilcox Co., 92 Ohio App.3d 603, 604 (9th Dist. 1993).

{¶9} In relevant part, Section 4112.02(I) prohibits any person from discriminating “in

any manner against any other person because that person has opposed any unlawful discriminatory

practice . . . .” “To establish a case of retaliation, a claimant must prove that (1) she engaged in a

protected activity, (2) the defending party was aware that the claimant had engaged in that activity,

(3) the defending party took an adverse employment action against the employee, and (4) there is

a causal connection between the protected activity and adverse action.” Greer-Burger v. Temesi,

2007-Ohio-6442, ¶ 13. 5

{¶10} Regarding whether Ms. Whitney engaged in a protected activity, she argues that

she engaged in protected activity when she opposed “unlawful investigatory tactics” that were

being employed by the compliance department. In its motion for summary judgment, JMS argued

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