A Bloomington woman who sued State Farm for wrongful firing, retaliation, and a hostile workplace environment caused by racism has had part of her case restored after a lower court tossed it out.
State Farm fired Carla Campbell-Jackson for sending personal client data and confidential company documents to her personal email address violating client confidentiality. A federal appeals court said the firing itself is OK. State Farm has fired others for similar infractions. The court noted, though, documents suggest the investigation had been closed without a firing, before Campbell-Jackson complained about a racist letter sent to State Farm workers.
“The prolonged delay between State Farm’s discovery of her policy violations and her termination, Campbell-Jackson argues, undercuts the company’s proffered reason for its adverse employment action. A reasonable juror could agree,” wrote the court.
State Farm fired Campbell-Jackson two weeks after she complained. The court ruled jurors should be able to take a look at that timing and decide whether that constitutes retaliation.
“Where an adverse employment action occurs very close in time after an employer learns of a protected activity, such temporal proximity between the events is significant enough to constitute evidence of a causal connection for the purposes of satisfying a prima facie case,” wrote the appeals court.
The court also rejected State Farm's assertion Campbell-Jackson couldn't sue over a hostile workplace environment because that allegation wasn't in an earlier complaint filed with the Equal Employment Opportunity Commission. The court called State Farm's reasoning "myopic." The court ruled that Campbell-Jackson should not be penalized just because the EEOC investigation wasn't broad enough.
“This one-issue EEOC claim does not cover all possible forms of race discrimination in the workplace,” said the court panel. “Campbell-Jackson’s race discrimination claim is better understood as alleging that she experienced racially harassing actions that created a hostile work environment. Indeed, she directly articulated as much in her charge.”
The court ruled that Campbell-Jackson should not be penalized just because the EEOC investigation wasn't "broader in scope."
“Moreover, State Farm offers scant reasoning as to why Campbell-Jackson’s earlier complaints must solely be considered as 'background' information rather than factual allegations of harassment, and we discern no reason for doing so here,” wrote the judges. “Her complaint adequately set forth a claim encompassing purportedly harassing activity between 2014 and 2016. The district court erred when it cabined Campbell-Jackson’s harassment claim to the events relating to the April 25 letter.”
State Farm had also claimed that the only instance of discrimination Campbell-Jackson had direct knowledge of was the racist letter and that the letter alone is not enough to establish the hostile workplace environment claim.
“We have long rejected a “myopic view of harassment” that limits such claims “only to those things that are ‘directed at or witnessed by’” a particular plaintiff,” wrote the panel. “Campbell-Jackson’s secondhand knowledge of discriminatory conduct in the workplace can support a hostile work environment claim.”
Campbell-Jackson’s attorney issued a statement on her behalf Thursday saying she is pleased with the ruling in her favor.
“As I remained resolute, determined and steadfast regarding my posture. State Farm created an extremely hostile work environment and retaliated against me after I expressed concerns and consternation about the disparaging treatment of minority State Farm employees and minority State Farm policyholders and claimants. Disclosing State Farm’s decades of illegal practices required courage, commitment, and an unwavering determination embedded in justice. I am proud to advocate on behalf of thousands of disenfranchised minority employees, insureds, and claimants,” said Campbell Jackson.
State Farm issued a statement about the ruling: "We believe the district court appropriately decided the case and are pleased the appellate court affirmed the dismissal of the race-based termination claim. While disappointed in the partial reversal, we note the appellate court ruled merely that it was premature to determine those aspects of the case, and we believe that those aspects will ultimately be decided in favor of State Farm."
