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Watson v. State, Department of Correction

United States District Court, N.D. Indiana, South Bend Division

February 20, 2019




         Antania Watson filed this action alleging that the State of Indiana Department of Correction (IDOC) discriminated against her on the basis of her race and sex when it terminated her employment as a corrections officer. Upon the close of discovery, IDOC moved for summary judgment, arguing that neither Ms. Watson's race nor her sex contributed to the decision to fire her. For the following reasons, the Court grants the motion for summary judgment.


         Ms. Watson applied for employment with IDOC as a correctional officer at Indiana State Prison in November 2014. A mandatory pre-interview questionnaire required Ms. Watson to indicate whether she had any known relatives incarcerated in the IDOC. In response, Ms. Watson indicated that she had a sibling named “Victor Blissitt” incarcerated at either Indiana State Prison or Westville Correctional Facility. Ms. Watson also indicated on the same questionnaire that she had previously visited an IDOC inmate, against listing an individual by the name of “Victor Blissitt.” Ms. Watson was hired by IDOC and subsequently began attending the required training for new correctional officers.

         On December 11, 2014, the training class covered the topic of trafficking contraband in prison. During a break from the training several of the students were discussing that topic. Ms. Watson allegedly made several comments that her classmates found concerning and reported to Internal Affairs. The reports, submitted by four of her classmates, alleged that Ms. Watson “stated that she knew of offenders who had cell phones in [Indiana State Prison], ” that “she believed if she were to traffic, inmates would not snitch on her, they only snitch on other offenders, ” and that “trafficking isn't really a big deal.” [DE 97-2 at 10-15].

         Those reports were forwarded to the warden of Indiana State Prison, who instructed Internal Affairs to investigate. Specifically, the warden emailed two Internal Affairs investigators stating “I'd like this employee seriously interviewed before she begins on shift. If this is true, I don't want her and would like to cut our losses but I need something more than the three staff witness statements.” [DE 92-15 at 2]. Ms. Watson was interviewed by Internal Affairs on December 15, 2014. Ms. Watson denied making the statements in question and denied knowing any inmates who had cellphones. She also said that she believed her classmates were stereotyping her as someone prone to trafficking with offenders because “she is cute” and “offenders will ‘hit' on her.” [DE 92-15 at 1]. In a statement written after the interview, Ms. Watson indicated that she believed she may have been “misinterpreted” and that her classmates' reports were motivated by their stereotype of her being likely to engage in trafficking because, as a female, she would be an easy target for manipulation by offenders. [DE 97-2 at 7].

         During the December 15 interview, the investigators also questioned Ms. Watson about the sibling listed on her job application. Ms. Watson said her brother's name was “Victor Blissitt” and that he was incarcerated at either Indiana State Prison or Westville Correctional Facility, and that she last visited him in 2012. While Ms. Watson was writing her statement after the interview, the investigators found a visitation application dated July 11, 2009, showing that Ms. Watson had visited “Victor Crews” at Indiana State Prison. The application was signed by Ms. Watson and stated that she was his sister. Visitation records showed that Ms. Watson visited Crews at Indiana State Prison four times between 2010 and 2012. Upon discovering that information, one of the investigators asked Ms. Watson “who Offender Crews was.” [DE 92-2]. She replied that she did not know. He asked her again whether she knew who Crews was, and she replied “no.” Id. Records further showed that Crews was suspected of trafficking cell phones into the facility and had recently been found in possession of a contraband cell phone.

         The Internal Affairs investigators concluded their investigation at that point. They concluded that they were unable to substantiate the initial reports about Ms. Watson's statements about trafficking. However, they concluded that Ms. Watson had falsified her employment application and failed to fully disclose her relationship to an inmate, as she identified her brother as Victor Blissitt and denied knowing Crews. On December 18, 2014, the warden met with Ms. Watson and terminated her employment. The termination letter stated that Ms. Watson was fired because her “actions [did] not meet agency standards and [were] unacceptable.” [DE 92-3]. The warden asserts that he terminated Ms. Watson's employment “because she failed to disclose in her employment application that her brother, Victor Crews, is incarcerated at [Indiana State Prison].” [DE 92-1]. He asserted that he would terminate the employment of any correctional officer who failed to fully disclose the identity of a family member incarcerated at the facility, since that not only demonstrates dishonesty, but may also suggest an improper motive.

         Ms. Watson later filed this suit against IDOC. She initially represented herself, but the Court granted her motion to recruit counsel, so she is now ably represented. Discovery has closed, and IDOC moved for summary judgment.


         Summary judgment is proper when 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.” Fed.R.Civ.P. 56(a). A “material” fact is one identified by the substantive law as affecting the outcome of the suit. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A “genuine issue” exists with respect to any material fact when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. Where a factual record taken as a whole could not lead a rational trier of fact to find for the non-moving party, there is no genuine issue for trial, and summary judgment should be granted. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986) (citing Bank of Ariz. v. Cities Servs. Co., 391 U.S. 253, 289 (1968)). In determining whether a genuine issue of material fact exists, this Court must construe all facts in the light most favorable to the non-moving party and draw all reasonable and justifiable inferences in that party's favor. Jackson v. Kotter, 541 F.3d 688, 697 (7th Cir. 2008); King v. Preferred Tech. Grp., 166 F.3d 887, 890 (7th Cir. 1999). However, the non-moving party cannot simply rest on the allegations contained in its pleadings but must present sufficient evidence to show the existence of each element of its case on which it will bear the burden at trial. Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986); Robin v. Espo Eng'g Corp., 200 F.3d 1081, 1088 (7th Cir. 2000).


         Ms. Watson's complaint suggested that she was asserting claims for race and sex discrimination in violation of Title VII. The Indiana Department of Correction moved for summary judgment on both claims. In response, Ms. Watson only defends her claim for sex discrimination. The Court thus construes her as abandoning any claim for race discrimination. For many of the same reasons discussed below, though, the record contains no evidence to support a claim for race discrimination, so summary judgment would be warranted on the merits as well.

         Title VII prohibits an employer from discriminating based on an individual's “race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a). A Title VII claim requires a plaintiff to show (1) they are a member of a class protected by the statute; (2) they have experienced an adverse employment action; and (3) the employer took this adverse action because of the plaintiff's membership in the protected class. Abrego v. Wilkie, 907 F.3d 1004, 1012 (7th Cir. 2018). The parties do not dispute that Ms. Watson is a member of a protected class and that she was subject to an adverse ...

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