Plaintiff, Rohan Peters, an African-American Pilot sued his former employer, International Paper Company (“International Paper” or “Defendant”), alleging claims of wrongful termination and retaliation arising out of Defendant’s discrimination pursuant to Title VII of the Civil Rights Act of 1964. Defendant filed a Motion for Summary Judgement on May 31, 2023. The Court granted summary judgement in favor of Defendant on Plaintiff’s racial discrimination claims and on Plaintiff’s entitlement to certain categories of damages on December 28, 2023.
International Paper filed a motion to exclude the testimony of Plaintiff’s proffered opinion witness, sociology professor Dr. Matthew Hughey, pursuant to Daubert and Federal Rule of Evidence Rule 702. International Paper also renewed its motion to preclude Peters from mentioning or introducing evidence related to the expert opinion, testimony, and report of Matthew Hughey at any point during the proceedings.
Human Resources Expert Witness
Matthew Hughey specializes in race and ethnicity, bias, discrimination, racism, culture, media, organizations, religion, and science. He hold a B.A. (Bachelor of Arts) in sociology from the University of North Carolina, Greensboro; a certificate of advanced graduate study in “women’s studies” from Ohio University; an M.Ed. (Master of Education) in cultural studies from Ohio University; a graduate certificate in “religions of the world” from Harvard University; an A.L.M. (Artibus Liberalibus Magistri | Master of Liberal Arts) in religion from Harvard University, and a Ph.D. (Doctor of Philosophy) in sociology (with a specialization in race and culture) from the University of Virginia. He has been on the faculty of the University of Connecticut since 2013. He is full Professor of Sociology (2020-present) and was previously Associate Professor of Sociology (2013-2020). Before then he was Assistant Professor of Sociology at Mississippi State University (2009-2013). He also serves as adjunct faculty at the University of Connecticut in (1) the Sustainable Global Cities Initiative program, (2) for the Graduate Certificate and Masters in Race, Ethnicity, & Politics (REP) program, (3) the Institute for Collaboration on Health, Intervention, & Policy (InCHIP), (4) the American Studies Program, and (5) the Africana Studies Institute.
Discussion by the Court
Defendant contended that Hughey’s testimony improperly substituted his own judgment in place of that of the jury, effectively instructing them on the legal conclusions they should draw. They argued that Hughey lacked adequate qualifications in workplace discrimination and retaliation, with minimal relevant experience. Additionally, Defendant claimed that Hughey’s opinions lacked a solid factual basis, relied on unreliable methodologies, and failed to apply his principles effectively to the specifics of the case. Defendant pointed out that Hughey’s CV lacked relevant sources relating to retaliation, and they criticized his analysis for typographical errors revealing copy-and-paste analysis from prior cases, suggesting a lack of meaningful application to the case’s facts. Furthermore, Defendant argued that Hughey’s references to the Ku Klux Klan and incidents of police brutality were unfairly prejudicial.
Plaintiff refuted the Defendant’s claims and found fault with Defendant’s alleged mischaracterization of Hughey’s report, especially its conclusion that racial prejudice likely influenced the Plaintiff’s treatment by Defendant. They asserted that Hughey’s CV qualified him to offer opinions on race-related issues. Additionally, Plaintiff argued that the case’s complexity necessitated expert opinion witnesses, as laypeople might not grasp all the intricate details.
The Court noted the underlying emphasis on Hughey’s proffered testimony about racial discrimination which provided historical context, analysis, and conclusions applicable to the racial discrimination claim in this case. Indeed, retaliation was only discussed as a basis for Hughey’s ultimate conclusion that Plaintiff experienced racial discrimination. The Court had previously granted Defendant’s summary judgment motion with respect to Plaintiff’s race discrimination claim. Henceforth, Plaintiff’s claims for racial discrimination were not before the jury, having been dismissed at the summary judgment stage. As a result, the sole remaining claim in this case was Plaintiff’s retaliation claim.
Hughey’s fifty-nine (59) page report mentioned retaliation a total of four (4) times. Among these, two instances were merely recitations of the plaintiff’s claims, while the other two a section and a phrase, respectively, were used to support the conclusion regarding racial discrimination. The four-page section labeled “Racial Gaslighting and Retaliation” comprised one and a half pages of block quotes, one page summarizing the concept of gaslighting, one and a half pages providing a summary of alleged facts, and concluded with sentences stating:
“A company wishing to avoid conflict of interest and to engage in fair, equitable, and transparent employment practices would not have a subject of the complaint oversee disciplinary measures over the complainant. The action likely sent a message of intimidation with the implicit meaning to drop past, and/or avoid future, complaints.”
The Court citing Curtis v. Oklahoma City Public Schools Bd. of Educ., 147 F.3d 1200 (10th Cir. 1998), held that Hughey’s failure to address matters beyond common knowledge or experience of the average layperson was highlighted in his section on retaliation, which offered only a single, limited conclusion without supporting citations or analysis regarding the bases, methods, or principles applied to reach that conclusion.
Held
Matthew Hughey’s opinion on retaliation, to the extent it existed, did not involve analysis or application of any methodology which led the Court to exclude it. Defendant’s renewed motion to preclude Peters from mentioning or introducing evidence related to the expert opinion, testimony, and report of Hughey was deemed moot.
The Court has not arrived on an outcome for this case since the remaining issues involved in this case still await resolution.
Key Takeaways:
Defendant disputed the qualifications and methodology of Hughey, alleging that his testimony improperly substituted his judgment for that of the jury and lacked a solid factual basis. In response, the Plaintiffs argued that Hughey was indeed qualified to offer opinions on race-related issues, asserting the relevance of his expertise to the case’s complexities. They emphasized the need for expert opinion witnesses to help comprehend intricate details beyond laypeople’s grasp. While Hughey’s testimony primarily focused on racial discrimination, it briefly addressed retaliation, albeit in a limited manner, which became a point of contention. The Court criticized Hughey’s report for lacking detailed analysis and support regarding retaliation, citing legal precedent to underscore the importance of thorough expert testimony, especially in complex matters like retaliation in employment discrimination cases.
Case Details:
| Case Caption: | Peters V. International Paper Company |
| Docket Number: | 2:22cv2132 |
| Court: | United States District Court, Tennessee Western |
| Citation: | 2024 U.S. Dist. LEXIS 20731 |
| Date: | February 6, 2024 |
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