08-06-2025
Monica Gray worked for State Farm for fifteen years as a claims specialist. Her coworker, Sonya Mauter, reported to a different manager, Joe Kyle. Mauter had an ADA claim that exempted her from overtime work. Kyle placed her on leave until she agreed to work overtime and told her she would be fired if she did not. He told Mauter she had no leave available under FMLA (which was untrue). Mauter asked Gray to help her combat what Kyle was doing. Gray researched ADA law and State Farm policies, contacted HR for information, and lodged an internal complaint. Gray advised Mauter to find a lawyer and file an EEOC charge. Mauter told Kyle that Gray was helping her with the ADA issue. Shortly after, Kyle became a temporary supervisor for Gray. Kyle then closely scrutinized Gray’s timecards, reported discrepancies that he found, and encouraged an additional review by HR. Gray’s supervisor had been pretty relaxed about timecard policies. When HR went to Gray about the alleged timecard issues, she told them that Kyle was targeting her for helping Mauter. She asked whether Kyle had reviewed any other employee’s timecards. HR did not investigate her allegation of retaliation, and State Farm fired her for the timecard issues.
The Sixth Circuit Court of Appeals reversed the lower court’s summary judgment on Gray’s claims. It found sufficient evidence that Kyle’s stated reason for reporting her was pretextual, and she had raised a genuine dispute over his motives. The court pointed out that this case was not an example of prior performance issues that would prompt increased scrutiny. Instead, the heightened scrutiny came after Gray engaged in protected activity, “with no other prevailing reason to justify it.” While the HR decision to terminate Gray was neutral, the information was based on a biased subordinate’s input, commonly known as “cat’s paw” liability.