« Environment - Indiana Court of Appeals issues opinion providing guidance on seeking coverage for environmental liabilities | Main | Ind. Decisions - Supreme Court decides one today, involving termination of parental rights »

Thursday, July 10, 2014

Ind. Decisions - 7th Circuit decides a second Indiana case today, a reversal

In Stephanie Sue Carlson v. CSX Transportation (SD Ind., Young), a 26-page opinion, Judge Hamilton writes:

This appeal requires us to revis-it the pleading requirements for discrimination and retalia-tion claims under Title VII of the Civil Rights Act of 1964, including claims for retaliation where the employee alleges an ongoing pattern of retaliation. We must also clarify the scope and effect of the Railway Labor Act’s mandatory arbitration provision when an employee alleges discrimination or retaliation in violation of federal statutes.

Plaintiff Stephanie Carlson brought several sex discrimi-nation and retaliation claims under Title VII against her em-ployer, defendant CSX Transportation, Inc., a railway com-pany. She also brought a related contract claim based on the settlement she had reached with CSX of an earlier discrimi-nation lawsuit. CSX moved to dismiss, arguing that Carl-son’s claims were implausible and that some were precluded by the Railway Labor Act (RLA) because they were based on company decisions justified by the terms of a collective bar-gaining agreement.

For the most part, the district court agreed with CSX, dismissing the majority of Carlson’s claims for failure to state a claim upon which relief could be granted and finding that the RLA precluded the remaining claims. Carlson has ap-pealed. We conclude that none of her claims should have been dismissed. The allegations in her complaint are easily sufficient to state claims for sex discrimination and retalia-tion. And the RLA, which requires that claims arising under collective bargaining agreements in the railway and airline industries be decided in arbitration, does not preclude Carl-son’s claims, which arise under Title VII and a private con-tract between Carlson and CSX.

Upon granting CSX’s motion to dismiss, the district court also denied as moot a motion for summary judgment that CSX had filed while its motion to dismiss was pending. CSX has cross-appealed and asked us to grant summary judg-ment in its favor if we conclude (as we do) that the district court erred by dismissing Carlson’s claims on the pleadings. We decline to rule on the summary judgment motion that the district court did not consider. We remand the case for further proceedings. * * *

The district court’s dismissal of Carlson’s claims is REVERSED and the case is REMANDED for further pro-ceedings consistent with this opinion.

Posted by Marcia Oddi on July 10, 2014 02:26 PM
Posted to Ind. (7th Cir.) Decisions