In Wyatt v. Nissan North America, (6th Cir., No. 20-5021, 05/28/21), Plaintiff Wyatt, a Project Manager for Nissan, appealed the decision of Judge Richardson of the Middle District of Tennessee, which had granted summary judgment as to Wyatt’s various employment discrimination and retaliation claims under Title VII, the ADA and the FMLA. Wyatt argued that she had presented sufficient evidence from which a jury could find the employer subjected Wyatt to a hostile work environment due to unabated sexual harassment from a senior manager, discriminated against Wyatt because of her disabilities, and retaliated against Wyatt after she engaged in protected activity.
The Sixth Circuit Court of Appeals held the trial court had failed to view the record in the light most favorable to Wyatt, leading it to conclude erroneously that there were no genuine issues of material fact with respect to Wyatt’s hostile work environment claim brought under Title VII and retaliation claims brought under Title VII, the ADA, and the FMLA. The Sixth Circuit affirmed the trial court’s grant of summary judgment to Nissan with respect to Wyatt’s discrimination claim under the ADA and Wyatt’s retaliation claims insofar as they were based on retaliatory harassment. However, the Sixth Circuit reversed the trial court’s grant of summary judgment to Nissan with respect to Wyatt’s hostile work environment claim and Wyatt’s retaliation claims based on an adverse employment action, and remanded the case back to the trial court.