Lucille K. Melvin v. Car-Freshener Corporation

LAY, Circuit Judge,

dissenting.

I respectfully dissent. Melvin has presented sufficient evidence from which a reasonable jury could infer that she was terminated because her injury qualified her for workers’ compensation benefits. Although temporal proximity between protected conduct and discharge is insufficient to establish retaliation under Iowa law, Hulme v. Barrett, 480 N.W.2d 40, 43 (Iowa 1992), temporal proximity coupled with another aggravating factor, however undefined, can support an inference of retaliation for purposes of summary judgment. See Walters v. United States Gypsum Co., 537 N.W.2d 708, 712 (Iowa 1995).

Here, Melvin was laid off the same day she qualified for workers’ compensation benefits. Plant production coordinator Chris Walters stated Melvin was laid off because there were no positions available in the pack department. However, Car-Freshener rehired three individuals to work in the pack department just one week prior to Melvin’s layoff. Moreover, Walters later stated Melvin was not placed in the pack line due to concerns it would further aggravate her injuries.

Car-Freshener emphasizes its economic downturn as the reason for Melvin’s termination and the majority concludes Melvin cannot establish her engagement in a protected activity was the determinative factor in this case. However, I submit the inconsistencies in Car-Freshener’s explanations, coupled with the timing of Melvin’s termination, are enough evidence from which a reasonable jury could infer Melvin was terminated because she qualified for workers’ compensation benefits. “A factor is determinative if it is the reason that ‘tips the scales decisively one way or the other,’ even if it is not the predominate reason behind the employer’s decision.” Teachout v. Forest City Cmty. Sch. Dist., 584 N.W.2d 296, 302 (Iowa 1998) (emphasis added) (quoting Smith v. Smithway Motor Xpress, Inc., 464 N.W.2d 682, 686 (Iowa 1990)).

Too many courts in this circuit, both district and appellate, are utilizing summary judgment in cases where issues of *1004fact remain. This is especially true in cases where witness credibility will be determinative. In these instances, a jury, not the courts, should ultimately decide whether the plaintiff has proven her case. Summary judgment should be the exception, not the rule. It is appropriate “only ... where it is quite clear what the truth is, ... for the purpose of the rule is not to cut litigants off from their right of trial by jury if they really have issues to try." Poller v. Columbia Broad. Sys., Inc., 368 U.S. 464, 467, 82 S.Ct. 486, 7 L.Ed.2d 458 (1962) (emphasis added) (citation and internal quotations omitted).

It is undeniable that summary judgment is a valuable tool, the use of which allows overextended courts to remove cases that lack merit from their dockets. See Celotex Corp. v. Catrett, 477 U.S. 317, 327, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). However, in accomplishing this goal, we have an obligation not to “overlook[ ] considerations which make ... summary judgment an inappropriate means to that very desirable end.” Sartor v. Arkansas Natural Gas Corp., 321 U.S. 620, 627, 64 S.Ct. 724, 88 L.Ed. 967 (1944). As Justice Black explained,

The right to confront, cross-examine and impeach adverse witnesses is one of the most fundamental rights sought to be preserved by the Seventh Amendment provision for jury trials in civil cases. The advantages of trial before a live jury with live witnesses, and all the possibilities of considering the human factors, should not be eliminated by substituting trial by affidavit and the sterile bareness of summary judgment.

Adickes v. S.H. Kress & Co., 398 U.S. 144, 176, 90 S.Ct. 1598, 26 L.Ed.2d 142 (1970) (Black, J., concurring).

I express no opinion as to whether Melvin would ultimately be able to convince a jury in this case. However, she and all other similarly-situated plaintiffs should be afforded the opportunity to do so.