Brian Weibel v. Pregis LLC

Summary

The United States District Court for the Northern District of Mississippi considers Pregis LLC's motion for summary judgment in Brian Weibel's action alleging age discrimination under the ADEA and retaliatory discharge under Mississippi law. The opinion analyzes whether Weibel reported an actual criminal Clean Water Act violation and whether that report influenced his termination under a cat's-paw theory. The excerpt concludes that genuine factual disputes preclude summary judgment on the McArn retaliatory-discharge claim.

Holdings

1. Summary judgment was inappropriate because conflicting evidence created a genuine dispute as to whether the scrubber water reached an outfall and whether, if discharged, it qualified as an allowable non-stormwater discharge. Under McArn, the plaintiff need not prove the underlying criminal violation beyond a reasonable doubt at the summary-judgment stage.
2. Summary judgment was inappropriate because a reasonable jury could find that retaliation for Weibel's report of the alleged Clean Water Act violation played a role in his termination.
3. Pregis was entitled to summary judgment on the ADEA claim because Weibel failed to produce evidence from which a reasonable factfinder could conclude that age was the but-for cause of his termination.

Questions Presented

1. Whether genuine disputes of material fact existed as to whether Pregis committed an actual criminal Clean Water Act violation by discharging the floor-scrubber water.
2. Whether genuine disputes of material fact existed as to whether Weibel was terminated because he reported the alleged Clean Water Act violation under Mississippi's McArn public-policy exception.
3. Whether Weibel produced sufficient evidence for a reasonable factfinder to conclude that age was the but-for cause of his termination under the ADEA.

Disposition

other