In Gray v. State Farm Mutual Auto Insurance Co. (6th Cir., No. 24-3086, 07/25/2025), Gray sued for retaliation under the ADA. The district court granted summary judgment for the employer, and the Sixth Circuit reversed. In this case, a supervisor was alleged to have targeted Gray for assisting a coworker in their ADA advocacy. The district court dismissed the claim finding that the employer had reason to believe that Gray had engaged in misconduct. However, the Sixth Circuit found that the lower court had not analyzed the case from the vicarious liability/cat’s paw approach, and in doing so found that a fact issue existed as to whether Gray’s supervisor had a discriminatory motive in reporting Gray for the alleged misconduct – which the evidence showed was common practice in the workplace.
Sixth Circuit Reverses SJ on Potential Cat’s Paw Analysis
