Judge Stephanie Davis, who was nominated by President Biden to the Sixth Circuit, wrote a unanimous opinion that partly reversed a lower court and gave a long-time employee the opportunity to proceed on hostile work environment and retaliation claims against her corporate employer. The November 2024 decision was in Campbell-Jackson v State Farm Insurance.
What happened in this case?
Dr. Carla Campbell-Jackson, an African-American woman, worked for State Farm Insurance for nearly thirty years. Her career demonstrated “steady progress” with “increasing responsibility and status” in various management positions, and she ‘consistently earned positive performance evaluations” and “multiple promotions.” In 2014, she transferred to State Farm’s Special Investigative Unit (“SIU”) in Kalamazoo, Michigan, where she was responsible for vetting customer insurance claims for fraud.
In the two years she worked at SIU, significant problems developed. She observed and complained about State Farm employees who “regularly denied” insurance claims filed by African Americans and other minority customers, and also raised concerns about alleged discrimination against minority employees. In April 2016, she and others received a copy of a letter addressed to State Farm’s president that “contained racially offensive and derogatory language.” She alerted other employees and supervisors and tried to collect and dispose of other copies of the letter. Her supervisors stated, however, that this was “not [her] job” and she should “hold tight” while HR and others dealt with the situation. Campbell-Jackson’ performance evaluations also deteriorated significantly, about which she complained.
In May 2016, she was called to a meeting with several supervisors. They were clearly not satisfied with her performance, including her sending email to her personal account, for which she apologized but noted that other employees had done the same in order to work on such matters from home. At the end of the meeting, she was fired, with one supervisor stating that it was in the company’s “best interest” that she and State Farm “part ways.”
Campbell-Jackson filed discrimination claims with the EEOC, which concluded that she had viable claims for hostile work environment and retaliation. She then filed a complaint against State Farm in federal district court. After pretrial proceedings, the court granted summary judgment to the corporation and dismissed Campbell-Jackson’s complaint without a trial. She appealed to the Sixth Circuit.
How did Judge Davis and the Sixth Circuit rule and why is it important?
In a unanimous opinion, Judge Davis reversed the lower court and sent the case back to the district court so that Campbell-Jackson could proceed on her claims of hostile work environment and retaliation. Davis explained that the lower court had erred when it “limited the scope” of her harassment claims to the period around the April 2016 letter, as opposed to her allegations of a hostile work environment over “the course of many years.” Based on a careful review of the relevant facts and precedent, moreover, Davis concluded that a jury could “reasonably determine” that her firing was retaliatory and that State Farm’s justification was “pretextual.”
Judge Davis’ opinion is obviously important to Campbell-Jackson and her effort to get damages and justice from State Farm for the discrimination she suffered. The ruling may also be significant in other cases raising employment discrimination issues, particularly in the Sixth Circuit, which includes Kentucky, Michigan, Ohio and Tennessee. In addition, the decision serves as a reminder of the importance of confirming fair-minded judges to our federal courts