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Chandler v. Meeting & Events International, Inc.

United States District Court, S.D. Indiana, Evansville Division

April 14, 2015



WILLIAM T. LAWRENCE, District Judge.

This cause is before the Court on the Defendant's Motion for Summary Judgment (Dkt. No. 31) and the Plaintiff's Cross-Motion for Summary Judgment (Dkt. No. 39). The motions are fully briefed, and the Court, being duly advised, GRANTS IN PART the Defendant's motion and DENIES the Plaintiff's motion for the reasons, and to the extent, set forth below.


Federal Rule of Civil Procedure 56(a) provides that summary judgment is appropriate "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." In ruling on a motion for summary judgment, the admissible evidence presented by the non-moving party must be believed and all reasonable inferences must be drawn in the non-movant's favor. Hemsworth v., Inc., 476 F.3d 487, 490 (7th Cir. 2007); Zerante v. DeLuca, 555 F.3d 582, 584 (7th Cir. 2009) ("We view the record in the light most favorable to the nonmoving party and draw all reasonable inferences in that party's favor."). However, "[a] party who bears the burden of proof on a particular issue may not rest on its pleadings, but must affirmatively demonstrate, by specific factual allegations, that there is a genuine issue of material fact that requires trial." Id. Finally, the non-moving party bears the burden of specifically identifying the relevant evidence of record, and "the court is not required to scour the record in search of evidence to defeat a motion for summary judgment." Ritchie v. Glidden Co., 242 F.3d 713, 723 (7th Cir. 2001).

The fact that the parties have filed cross-motions for summary judgment does not alter the standard set forth in Federal Rule of Civil Procedure 56. When evaluating each side's motion, the Court simply "construe[s] all inferences in favor of the party against whom the motion under consideration is made." Metro Life. Ins. Co. v. Johnson, 297 F.3d 558, 561-62 (7th Cir. 2002) (quoting Hendricks-Robinson v. Excel Corp., 154 F.3d 685, 692 (7th Cir. 1998)).


Defendant Meetings & Events International, Inc. ("MEI") was founded in 1984 by Teresa Hall; it specializes in providing logistical support to medical professionals needing to plan events and also provides reporting services for its clients. Plaintiff Marybelle Chandler was hired by MEI in March of 1994; she was fifty-one years old at the time. Ms. Chandler held various positions with MEI; however, at the time of her termination, Ms. Chandler was a receptionist.

In early 2012, MEI experienced a severe decline in business income due, in part, to the passage of the Patient Protection and Affordable Care Act. After attempting to save money and reduce expenses via other means, Hall and her department heads-Jason McDowell, finance, Fred Wix, technology, Brian Kennalley, in-house counsel, and Crissy Kerney, vice president of client services-met in March 2012 to discuss reducing MEI's workforce. It was decided in June 2012 that a reduction in force was necessary. Each department submitted to Hall the names of two or three employees that they recommended for termination.

Thus, on July 27, 2012, Ms. Chandler attended a meeting with Hall and McDowell and was informed that her employment was being terminated due to financial reasons. In all, MEI terminated eleven individuals due to the reduction in force ("RIF"). After Ms. Chandler was terminated, her receptionist duties were assumed by Beverly Westerman and Nancy Latta.

Ms. Chandler filed a Charge of Discrimination with the EEOC on October 1, 2012, claiming that she was discriminated against based on her age and race.

In early 2013, the financial situation at MEI began to improve, and Hall authorized the department heads to begin rehiring as necessary to meet the demands of MEI's customers. Several individuals were asked to return to their former positions with MEI; however, Ms. Chandler was not called back. Similarly, MEI posted several open positions on career websites such as Career Builders. Ms. Chandler applied for a coordinator position in April 2013 through the Career Builders website, but was not interviewed or hired.

Ms. Chandler filed suit in this Court on October 25, 2013.


Ms. Chandler brings two claims in her Amended Complaint: 1) a discrimination claim under the Age Discrimination in Employment Act ("ADEA"), 29 U.S.C. § 621 et seq.; and 2) a retaliation claim pursuant to the ADEA, in violation of 29 U.S.C. § 623(d).[1] MEI moves for summary judgment on both claims; Ms. Chandler moves ...

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