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Monday, June 09, 2014

Ind. Decisions - 7th Circuit decided one Indiana case Friday, June 6th, a reversal

In Whitfield v. International Truck and Engine (SD Ind., Young), a 17-page opinion, Judge Cudahy writes:

This rather complex matter in-volves a failure to hire claim under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act. At the heart of this case is plain-tiff-appellant Matthew Whitfield’s application for an electri-cian position at one of defendant-appellee Navistar’s engine manufacturing plants. Whitfield is African-American, and prior to applying with Navistar, he worked as an electrician for various employers, including four years with the U.S. Navy. Navistar is a manufacturer of engines, among other equipment, and employed a number of electricians at the time of Whitfield’s application. * * *

Whitfield’s claim finally proceeded to a bench trial in June 2012. After the first day, Whitfield filed a submission regarding evidence from the earlier class trial, Allen, et al. v. International Trucking, in an attempt to introduce 59 exhibits and testimony from 19 trial exhibits. Navistar objected, and the district court took the issue under advisement, and the trial proceeded until completion. On July 31, 2013, the court issued its findings of fact and conclusions of law as well as an entry of final judgment. The court rejected Whitfield’s submission regarding evidence from the class trial, stating that Whitfield gave the court no authority to support admission of evidence from the class action. Further, the court found that Whitfield’s submission, proffered one day into trial, was untimely. The court then concluded that Whit-field’s evidence was insufficient to directly or indirectly prove discrimination. Specifically, the court determined that Whitfield’s evidence did not imply any discrimination, that Whitfield did not meet Navistar’s unstated qualifications for the job, and that he did not offer any compelling comparator evidence. Because we find the district court made several errors in analyzing Whitfield’s evidence, we now reverse. * * *

Apparently Navistar and the court did not understand that the chart reflects the total experience of Navistar’s electricians, thus showing that Whitfield was more qualified than several employees even after they received on-the-job training. The updated EEOC chart is clear and persuasive evidence that Whitfield was more qualified than many of the white electricians Navistar hired during the limitations period—the district court committed clear error in determining that Whitfield had failed to submit any comparator evidence regarding Navistar’s preferred qualifications. * * *

AFFIRMED in part, REVERSED in part, and REMANDED.

Posted by Marcia Oddi on June 9, 2014 08:44 AM
Posted to Ind. (7th Cir.) Decisions