Keith Coleman v. Soo Line Railroad Co. d/b/a Canadian Pacific Railway

Summary

In this employment-discrimination action, Keith Coleman, an African American locomotive engineer, alleged that Soo Line Railroad terminated him because of his race, retaliated against protected activity, discriminated based on age and disability, and failed to provide a reasonable accommodation. The United States District Court for the Northern District of Illinois granted the railroad’s motion for summary judgment, including on the race-discrimination claims and the unopposed age-discrimination claim. The opinion analyzes the McDonnell Douglas framework, the holistic approach required by Ortiz v. Werner Enterprises, and the elements of Title VII retaliation.

Holdings

1. Coleman failed to establish a prima facie case of race discrimination because he did not produce evidence that he was meeting CP's legitimate expectations or identify a similarly situated employee who received more favorable treatment. Independently, considering the evidence holistically under Ortiz, the record did not permit a reasonable factfinder to conclude that race caused either termination.
2. Coleman failed to establish retaliation because he offered no evidence that any protected activity was a but-for cause of his adverse employment actions. His email to CP's CEO was not protected activity because it did not complain of discrimination connected to a protected class or provide facts supporting such an inference.
3. Coleman failed to establish that CP violated the ADA's reasonable-accommodation requirement because his accommodation request did not request access to a CPAP machine or accommodation from overnight routes, and he presented no evidence that CP knew he needed those accommodations.
4. Summary judgment was granted on the age discrimination claim because Coleman did not oppose Defendant's motion.
5. Defendant was entitled to summary judgment on all claims because the record lacked evidence from which a reasonable jury could find for Coleman.

Questions Presented

1. Whether Coleman produced sufficient evidence to create a genuine dispute that CP terminated him because of his race.
2. Whether Coleman produced evidence that his protected activity was a but-for cause of his adverse employment actions, including whether his email to CP's CEO constituted protected activity.
3. Whether CP failed to reasonably accommodate Coleman's sleep apnea, diabetes, or high blood pressure by failing to ensure that he could access his CPAP machine or avoid an overnight route.
4. Whether Defendant was entitled to summary judgment on Coleman's unopposed age discrimination claim.

Disposition

other