Full 11th Circuit Weighs 'Loyalty and Trust' in Kia HR Rep's Retaliation Lawsuit
Judge Beverly Martin wrote for a 2-1 majority panel in favor of a human resources manager who claimed she was fired for protected activity.
October 03, 2019 at 06:04 PM
5 minute read
The original version of this story was published on Daily Report
A case before the full U.S. Court of Appeals for the Eleventh Circuit on actions by a human resources manager is drawing national attention from employment lawyers and business groups.
At issue is Andrea Gogel, an HR director who heard complaints that the company's Korean executives discriminated against women and Americans. At a certain point, she came to believe she was a victim herself and filed a complaint with the Equal Employment Opportunity Commission, which later received two more complaints from Kia employees.
Gogel was fired after company executives noticed the same Atlanta law firm represented her and the co-workers who filed claims within a month. A split Eleventh Circuit panel noted a company executive observed Gogel was "paid to prevent lawsuits," not encourage them.
U.S. District Judge Timothy Batten in Atlanta granted Kia's motion for summary judgment in 2016.
When Gogel appealed, the panel agreed with Batten on the dismissal of gender and national origin claims but split 2-1 in favor of reinstating Gogel's retaliation claim.
The fault lines are delineated between the majority decision by Circuit Judge Beverly Martin, who was joined by Senior Judge Diarmuid O'Scannlain of the Ninth Circuit, and the dissent by Senior Judge Julie Carnes of the Eleventh Circuit.
Martin cited a 1989 precedent instructing the court to balance the purpose of Title VII and its protection of claimants "against an employer's legitimate demands for loyalty, cooperation and a generally productive work environment."
Viewing the facts in the light most favorable to Gogel as required at this stage of litigation, Martin held that all Gogel did was provide a colleague with the name of an attorney she was considering hiring for herself. That would be protected activity for anyone who wasn't in human resources, Martin added, and under these circumstances Gogel was protected, too.
Carnes' dissent cited a 1980 precedent holding an employee's opposition to an employer's actions — in this case, alleged discrimination — isn't protected when expressing opposition makes her ineffective at her job.
"It is hard to argue that a high-ranking manager whose job duties include working to resolve employee disputes without litigation can be effective in that position if she instead solicits subordinates to sue the company," Carnes wrote.
The full court agreed to hear the matter Oct. 22, and legal positions are rolling in.
The EEOC supports Gogel, arguing her HR position is irrelevant, that a jury could find Kia fired Gogel for protected activity and that Kia executives' belief she was soliciting other suits doesn't apply in this case.
The National Employment Lawyers Association also backs Gogel, arguing Kia wants "a new exemption from Title VII's coverage that is contrary to the plain language of the statute."
Gogel is represented by Meredith Carter of Smyrna, Georgia, and Lisa Lambert of Atlanta.
Carter, who did not respond to a request for comment by deadline, used to work for the employment firm Barrett & Farahany, which was named in the dissent as the firm Gogel and the other Kia employees retained to sue the company. Amanda Farahany, the firm's managing partner, said Gogel took her case to Carter when she started her own firm.
"It's not uncommon," Farahany added, for multiple employees from one company to hire the same firm to pursue claims.
In their brief, Carter and Lambert argued similar points made by the EEOC and the employment lawyers' group. They rejected the district court;s decision accepting Kia's reason for firing Gogel — that they lost confidence in her "loyalty and trust" — as "nonretaliatory."
"Federal law is not subservient to an employer's desire for 'loyalty and trust,' " they wrote.
W. Jonathan Martin II and William Clifton III of Constangy Brooks, Smith & Prophete represent Kia, formally known as Kia Motor Manufacturing Georgia. They argued their client was entitled to fire Gogel.
"Although Gogel had an absolute right to pursue her own EEOC claims against KMMG, she did not have the right to abandon the critical responsibilities of her position and, instead, to encourage or solicit others to join her litigation," they wrote.
They said Gogel admits referring another employee to her attorney "but asserts that such conduct is protected under any and all circumstances. That is not the law."
Martin did not respond to a request to comment by deadline.
The 300,000-member U.S. Chamber of Commerce filed an amicus brief backing Kia, arguing Gogel's HR position was a critical factor in analyzing whether her actions were protected.
The Association of Global Automakers, represented by Lawrence Ashe Jr. and Justin Gunter of Parker, Hudson, Rainer & Dobbs, also back Kia.
"No one is attempting to exempt HR professionals from Title VII," they argued, while adding the law doesn't immunize employees "who refuse to perform their key job duties."
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