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Latif v. FCA U.S. LLC

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

February 11, 2019

JENA LATIF, Plaintiff,
v.
FCA U.S. LLC, Defendant.

          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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