Staub v. Proctor Hospital
United States Supreme Court
562 US 411 (2011)
Vincent Staub (plaintiff) was a hospital technician and military reservist at Proctor Hospital (defendant). His supervisor Janice Mulally and her supervisor Michael Korenchuk were openly hostile to his military duties, made comments suggesting his absences burdened the hospital, and wanted him fired. Mulally issued Staub a disciplinary warning; weeks later, Korenchuk told HR executive Linda Buck that Staub had violated it. Without letting Staub fully respond, Buck reviewed his file and fired him. A jury found Staub's firing was unlawfully motivated by discriminatory animus under the Uniformed Services Employment and Reemployment Rights Act (USERRA) and awarded damages, but the Seventh Circuit reversed, reasoning Proctor, as the actual decision-maker, wasn't liable for the supervisors' bias. Staub appealed.
Whether an employer can be held liable under USERRA when the ultimate decision-maker was not personally biased, but a biased supervisor's discriminatory act was a proximate cause of the adverse decision.