In Jackson v. Genesee County (MI) Road Commission (6th Cir., No. 20-1334, 05/27/2021) the plaintiff Jackson served as the Human Resources Director for the defendant Genesee County Road Commission (GCRC). Jackson claimed the GCRC discharged her in retaliation for her investigation of employees’ claims of racial discrimination and her attempts to ensure that GCRC’s contracts complied with equal employment opportunity (EEO) regulations. The trial court granted GCRC’s motion for summary judgment because Jackson failed to prove that she engaged in protected activity and that there was insufficient evidence of causation between her activity and her discharge.
The 6th Circuit concluded that the trial court committed two errors. First, it incorrectly found that Jackson did not engage in protected activity because her investigations into complaints of discrimination and enforcement of EEO policies were within her job responsibilities as human resource director. The court held Jackson’s investigations into employee complaints that GCRC’s Director of Equipment was discriminating against them because of race and Jackson’s enforcement of EEO policies were protected activities. Second, the court held the trial court erroneously found that Jackson had failed to demonstrate causation between her protected activities and discharge. Because there remained a genuine factual dispute whether GCRC proffered a nondiscriminatory reason for Jackson’s discharge, summary judgment on causation was improper.
Sixth Circuit Reverses Summary Judgment on HR Director’s Title VII Retaliation Claim
