Monroe v. Indiana Department of Transportation

Jeff Monroe (plaintiff) worked for the Indiana Department of Transportation (INDOT) (defendant) for 21 years. Monroe was a night-shift unit foreman who supervised 18 employees. In January 2013, seven or eight of Monroe’s subordinates reported to Monroe’s supervisor that Monroe had exploded at subordinates during a meeting. INDOT’s investigation of the complaints revealed that several of Monroe’s subordinates believed Monroe was volatile, intimidating, militaristic, and disrespectful. After the investigation began, Monroe told INDOT management that he had recently been diagnosed with posttraumatic stress disorder (PTSD). During a meeting in which four upper-level managers (the decisionmakers) ultimately decided to terminate Monroe, the decisionmakers questioned whether Monroe’s PTSD diagnosis was legitimate or conveniently timed for INDOT’s investigation. Monroe sued INDOT in federal district court, arguing in relevant part that INDOT’s termination constituted disability discrimination. Monroe alleged that INDOT’s stated reason for terminating Monroe—mistreatment of his subordinates—was pretextual. Additionally, Monroe argued that INDOT had not terminated three comparators—similarly situated employees who did not have disabilities—after the comparators mistreated coworkers. However, two of the comparators were disciplined at a time when INDOT employees had greater job protections. The third comparator, Jim Branson, was disciplined in 2012 for cursing once at coworkers and throwing a squeegee, and in 2013, Branson was demoted after a coworker claimed that Branson put his hands on the coworker. INDOT moved for summary judgment, and the district court granted the motion, dismissing Monroe’s case. Monroe appealed.