Staub v. Proctor Hospital
United States Supreme Court
131 S. Ct. 1186 (2011)
Vincent Staub (Staub) (plaintiff) worked as a hospital technician for Proctor Hospital (Proctor) (defendant). Staub was also a military reservist, which required him to perform military duties one weekend per month and two or three full-time weeks per year. At Proctor, Staub's supervisor, Janice Mulally and Mulally's supervisor, Michael Korenchuk, were hostile toward Staub’s military obligations. Mulally and Korenchuk made antagonistic comments suggesting Staub's military duties were a drain on hospital resources, and Mulally assigned Staub extra shifts without notice based on her belief that Staub should compensate the hospital for absences related to his military service. Korenchuk knew Mulally wanted Staub fired. Several months prior to Staub’s firing, Mulally gave Staub a formal disciplinary warning accusing him of violating hospital rules and imposing certain remedial requirements. Several weeks later, based on a co-worker’s complaint, Korenchuk informed Linda Buck, a Proctor human resources executive, that Staub had violated the disciplinary warning. Before Staub could contest the accusation, Buck reviewed Staub’s personnel file and decided to fire him. Staub challenged his firing through Proctor’s internal channels, claiming that Mulally and Korenchuk had falsely accused him of violating the disciplinary warning due to their hostility toward his military status. When Buck refused to reverse the decision, Staub sued Proctor under the Uniformed Services Employment and Reemployment Rights Act of 1994 (the USERRA), 38 U.S.C. §4301 et seq., alleging he was fired as a result of unlawful discrimination based on his military service. A jury found that Staub’s firing was unlawfully motivated by discriminatory animus and awarded Staub damages, but the United States Court of Appeals for the Seventh Circuit reversed, concluding that Proctor, as the ultimate decision-maker, was not liable for Mulally’s and Korenchuk’s discriminatory conduct. Staub appealed.
Rule of Law
Holding and Reasoning (Scalia, J.)
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