United States District Court, S.D. Indiana, Indianapolis Division
ENTRY ON DEFENDANT'S MOTION FOR SUMMARY
JUDGMENT
James
R. Sweeney II, Judge
Plaintiff Jena Latif (“Latif”) brings this suit
against Defendant FCA U.S. LLC (“FCA”), alleging
race, gender and disability discrimination, and retaliation
claims under the Civil Rights Act of 1866, 42 U.S.C. §
1981 (“Section 1981”), the Americans with
Disabilities Act, 42 U.S.C. § 12101 (“ADA”),
and Title VII of the Civil Rights Act of 1964, 42 U.S.C.
§ 2000e et seq. (“Title VII”). FCA
now seeks summary judgment on all of Latif's claims. In
April 2018, the Court granted Latif's counsels'
motion to withdraw. Latif now proceeds pro se.
FCA's
Motion for Summary Judgment (ECF No. 47) is fully
briefed and ripe for decision. After carefully reviewing the
motion, response, reply, and relevant law, the Court
concludes that the motion should be GRANTED.
I.
Summary Judgment Standard
A
motion for summary judgment asks the Court to find that a
trial is unnecessary because there is no genuine dispute as
to any material fact and, instead, the movant is entitled to
judgment as a matter of law. SeeFed. R. Civ. P.
56(a). A disputed fact is material if it might affect the
outcome of the suit under the governing law. Hampton v.
Ford Motor Co., 561 F.3d 709, 713 (7th Cir. 2009). In
other words, while there may be facts that are in dispute,
summary judgment is appropriate if those facts are not
outcome-determinative. Harper v. Vigilant Ins. Co.,
433 F.3d 521, 525 (7th Cir. 2005).
In
ruling on a motion for summary judgment, the Court views the
facts in the light most favorable to the non-moving party and
all reasonable inferences are drawn in the non-movant's
favor. Ault v. Speicher, 634 F.3d 942, 945 (7th Cir.
2011). After the moving party demonstrates the absence of a
genuine issue for trial, the responsibility shifts to the
non-movant to “go beyond the pleadings” and point
to evidence of a genuine factual dispute precluding summary
judgment. See Celotex Corp. v. Catrett, 477
U.S. 317, 324 (1986). “If the non-movant does not come
forward with evidence that would reasonably permit the finder
of fact to find in her favor on a material question, then the
court must enter summary judgment against her.”
Waldridge v. Am. Hoechst Corp., 24 F.3d 918, 920
(7th Cir. 1994) (citing Matsushita Elec. Indus. Co. v.
Zenith Radio Corp., 475 U.S. 574, 585-87 (1986).
II.
Background
FCA
hired Latif, an African American woman, in 1995 (ECF No.
48-2 at 4), and promoted her to Team Leader in 2010.
(ECF No. 48-1, Ex. A ¶ 6.) Team Leaders are
appointed and removed by the Joint Team Leader Selection
Committee (“Selection Committee”), which
comprises representatives from FCA and the International
Union, United Automobile, Aerospace and Agricultural
Implement Workers of America (the “Union”).
(ECF No. 48-1, Ex. A ¶ 10.) As a Team Leader,
Latif managed between nine and eleven team members and
assisted team members with their daily job duties. (ECF
No. 48-1, Ex. A ¶ 7.)
In
January 2014, members of Latif's team complained about
her performance as Team Leader and requested a private
meeting with the Union representative on the Selection
Committee to discuss Latif's removal from the position.
(ECF No. 48-1, Ex. A ¶ 12.) Team member
complaints comprised remarks about Latif's poor
leadership skills, such as:
• “I think she's just not cut out to be a
[Team Leader].”
• “Latif can't drive a truck, has difficulties
getting things done timely.”
• “Has difficulty doing Team Leader job
[duties].”
• “[Latif has] [n]o understanding of the
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