In Godwin v. WellStar Health System, Inc., Mary Godwin had been working as an order puller for WellStar Health Systems since 1999. By 2003, she had been promoted to the position of Buyer in WellStar’s Purchasing Department. Her duties included processing orders with outside vendors for goods made by WellStar’s different departments. In 2009, WellStar hired a new Vice President of the Supply Chain, Tony Trupiano, whose job included overseeing the Purchasing Department. Soon after, Godwin’s supervisor expressed concerns to Trupiano about Godwin’s performance, noting that she had made some errors with purchase orders. Later that year, the supervisor conducted an evaluation of Godwin and found her to be “below expectations.” Soon after, that supervisor left and a new one was hired, Ken Tifft. Tifft read the former supervisor’s comments on Godwin, but thought they lacked documentation, and thus approved a merit pay increase for Godwin. However, Tifft would later come to share the view that Godwin was performing “below expectations.”
In September 2010, Godwin was placed on a 90-day performance improvement plan, with follow-up consultations after 30 and 60 days. Each time, her supervisor noted improvement, but also continued concerns. Godwin was eventually placed on a second 90-day plan in February 2011. Later that month, Godwin provided her supervisor with a letter from her doctor stating that due to her arthritis, she needed to move around every hour. Her supervisor responded that Godwin needed to remain visible in the Purchasing Department, which was large enough to walk through. However, Godwin, then 63 years old, complained to the Human Resources Department that her supervisor’s comments were ageist and there was no accommodation of her need to walk.
Godwin was eventually terminated from her position in June 2011. She filed a lawsuit against her employer alleging violations of the Age Discrimination in Employment Act (ADEA) and the Americans With Disabilities Act (ADA). Her employer responded by filing a motion for summary judgment, claiming that its actions were because of Godwin’s repeated performance problems, not any animus based on age or disability. Godwin responded that while Trupiano may not have had animus, he was the “cats paw” of Godwin’s direct supervisor, who did harbor animus toward her.
Under the “cats paw” theory, the unlawful animus of a supervisor could be imputed to the employer. It involves an employer essentially rubber stamping a subordinate supervisor’s decisions without conducting a separate investigation. The court considered whether the “cats paw” theory had merit and found that it did not. The evidence showed that Trupiano independently reviewed Godwin’s purchase orders and was involved with the decision to terminate Godwin’s employment. Therefore, the court rejected Godwin’s claim and sided with her employer.
The court also rejected Godwin’s ADA claim, finding that her supervisor’s requirement that she remain in the Purchasing Department did not amount to failure to accommodate her disability. The court thus found in favor of Godwin’s employer on the summary judgment motion.
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