Staub v. Proctor Hospital
Issues
Can the unlawful intent of employees who influence employment actions, but who do not make final decisions or act as a singular influence on the ultimate decision maker, be considered in employment discrimination suits?
In 2008, Vincent Staub received a favorable jury verdict in an employment discrimination trial against his former employer, Proctor Hospital. Proctor Hospital appealed to the Seventh Circuit Court of Appeals which reversed the verdict based on the "cat's paw" theory of employer liability. The court held that unless the ultimate decision maker was under the "singular influence" of another employee, only the decision maker's unlawful reasons for adverse employment decisions are actionable. The Supreme Court granted certiorari to decide whether the motivations of other employees who influence employment actions, but do not make the ultimate decision, may be taken into consideration in employment discrimination suits.
Questions as Framed for the Court by the Parties
In what circumstances may an employer be held liable based on the unlawful intent of officials who caused or influenced but did not make the ultimate employment decision?
In 2000, Vincent Staub, a veteran member of the United States Army Reserve, was employed by Proctor Hospital as an angiography technologist. See Staub v. Proctor Hospital, 560 F.3d 647, 651 (7th Cir.
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Additional Resources
· Supreme Court Insider, Debra S. Katz and Michael A. Filoromo III: Commentary: Will Justices Claw at 'Cat's Paw' Theory of Employer Liability? (Sept. 22, 2010)
· Equal Justice Society, Keith Kamusagi: EJS Joins Lawyers’ Committee in Filing Brief with U.S. Supreme Court in Staub v. Proctor Hospital (July 14, 2010)
· Hernblawg: The Cat’s Paw (May 6, 2010)