Douglas Holloway v. Soo Line Railroad Company

Summary

The Seventh Circuit affirmed summary judgment for the railroad on a Federal Railway Safety Act retaliation claim, holding that an employee cannot prove causation under 49 U.S.C. § 20109(a)(4) solely by showing a temporal sequence of injury report followed by termination. The court required "something more" — direct or circumstantial evidence of improper motive — and found that the plaintiff's extensive disciplinary history, not his injury report, drove the firing. The court also rejected a comparator argument because the other employee who reported the same injury had a clean record, which reinforced that the plaintiff was terminated for his prior violations.

Holdings

1. Holloway cannot rely solely on the temporal sequence of events (injury report followed by termination) to establish that his report was a contributing factor; he must present evidence of improper motive, which he failed to do.

Questions Presented

1. Whether Holloway presented sufficient evidence to show that his reporting of his workplace injury was a contributing factor to his termination under the Federal Railway Safety Act, 49 U.S.C. § 20109(a)(4).

Disposition

affirmed