Sykes v. Chattanooga Housing Authority

Summary

The Tennessee Supreme Court reviewed retaliatory-discharge claims brought by former Chattanooga Housing Authority employees under the Tennessee Public Protection Act and the Tennessee Human Rights Act. The court affirmed summary judgment for the defendants on the statutory whistleblower claims because the plaintiffs could not establish that their protected activity was the sole cause of their terminations, but reversed summary judgment on the THRA claims because disputed facts existed regarding causation. The case was remanded.

Holdings

1. A claimant under Tennessee Code Annotated section 50-1-304 must prove that the employer terminated the claimant solely for refusing to participate in or remain silent about illegal activity. Because undisputed evidence established legitimate reasons for terminating both plaintiffs and the plaintiffs could not show a genuine issue of material fact on sole causation, summary judgment for defendants was proper.
2. A THRA retaliation claimant need show only a causal connection between protected activity and materially adverse employment action, not that the protected activity was the sole cause of the termination. Because both plaintiffs identified genuine issues of material fact regarding retaliatory causation, summary judgment on the THRA claims was improper.
3. Tennessee courts must apply the ordinary Tennessee summary-judgment standard in retaliatory-discharge cases rather than the federal McDonnell Douglas framework for allocating burdens and ordering proof.

Questions Presented

1. Whether summary judgment was proper on the plaintiffs' retaliatory-discharge claims under the Tennessee Public Protection Act.
2. Whether summary judgment was proper on the plaintiffs' retaliatory-discharge claims under the Tennessee Human Rights Act.
3. What causation standard applies to retaliatory-discharge claims under the Tennessee Public Protection Act and the THRA.
4. Whether the Tennessee summary-judgment standard, rather than the federal McDonnell Douglas burden-shifting framework, governs these claims.

Disposition

affirmed