Black Worker Issued Warning Has Claim Based on ‘Cat’s Paw’ Doctrine, Court Rules

A black warehouse employee given a final written warning after engaging in horseplay with a white co-worker has triable discrimination claims under Title VII of the 1964 Civil Rights Act and Tennessee law under a “cat’s paw” theory because a white human resource director’s racial bias was a proximate cause of the discipline, the U.S. Court of Appeals for the Sixth Circuit ruled July 13 (Chattman v. Toho Tenax Am. Inc., 6th Cir., 10-5306, 7/13/12).

Reversing summary judgment to Toho Tenax America Inc. of Rockwood, Tenn., the court said Everett Chattman established a prima facie case of ...