After several years of conflicting lower court decisions, the U.S. Supreme Court, in Staub v. Proctor Hospital, finally offered clarifying guidance on when and whether a supervisor’s impermissible motive may be imputed to employers in employment discrimination cases.
Case background
Vincent Staub worked as a technician for Proctor Hospital. Staub served in the Army Reserve. His immediate supervisor, Janice Mulally, and her supervisor, Michael Korenchuk, were both hostile to Staub’s military obligations because it disrupted staffing. Mulally openly complained about the strain that Staub’s duties caused the hospital, and publicly discussed her desire to “get rid” of him. Korenchuk derided Staub’s military service.
In January 2004, Mulally cited Staub for failing to remain in his work area after treating a patient, based on a work rule that apparently did not even exist. Regardless, Staub was advised to keep Mulally or Korenchuk advised as to his whereabouts at all times. In April 2004, Korenchuk reported to Linda Buck, the company’s vice president of human resources, that Staub had left his desk without advising a supervisor. Relying upon Korenchuk’s report, Buck terminated Staub after she reviewed his file.
Staub filed suit under the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), alleging that the termination decision was motivated by hostility to his military service. He alleged that he had left Korenchuk a voice-mail regarding his whereabouts. A jury returned a verdict in his favor and awarded him $57,640 in damages.
On appeal, the U.S. Court of Appeals for the 7th Circuit reversed, holding that Mulally’s and Korenchuk’s alleged impermissible motives could not be imputed to Proctor Hospital because Buck had conducted her own investigation by reviewing Staub’s personnel file, and her decision was not “wholly dependent on a single source of information.”
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