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How a “Reasonably Informed” Investigation Saved This Employer in Court
Employers often worry that if they don’t run a picture-perfect investigation, a court will second-guess their decision. The Sixth Circuit just reminded everyone that the law doesn’t demand perfection; it demands reasonableness. And one employer’s measured, fact-based approach was enough to win.
TL;DR: A truss manufacturer fired a production-line employee after learning he admitted to painting graffiti on trusses that went to customers. The employee, who had a chronic knee injury, sued for disability discrimination and workers’ comp retaliation. The Sixth Circuit sided with the company, holding that its decision was “reasonably informed and considered” under the honest-belief rule. When an investigation is sound and supported by facts, a court won’t call it pretext.
From injured driver to accused vandal
A long-time delivery driver for a truss manufacturer claimed a disability from a chronic left-knee injury that made climbing painful and caused him to limp. After returning from medical leave, his supervisor moved him to a lower-paying production-line role that didn’t require climbing.
Soon after that reassignment, customers began complaining that trusses were arriving with graffiti: smiley faces, some with devil horns, and pairs of circles with dots that looked like female breasts. The company’s plant manager took the complaints seriously. He found more graffiti at the facility, ruled out the second shift, and asked the first-shift supervisor to investigate. When the supervisor questioned workers, one employee said, “I did it.” The supervisor reported that admission, and the manager fired the employee the same day for defacing company property, relying on a rule that allowed discharge for that offense.
The employee later sued, claiming the company used the graffiti as a pretext to discriminate against him because of his knee injury and to retaliate for his prior workers’ comp claims.
The Sixth Circuit: reasonableness, not perfection
The Sixth Circuit affirmed summary judgment for the employer. The key was the honest-belief rule, which protects employers who make decisions based on “reasonably informed and considered” judgments, even if the employee insists the decision was wrong. The plant manager didn’t need a full-scale internal investigation; he only needed credible facts supporting his conclusion.
The court noted that the manager:
- Investigated customer complaints and verified the graffiti on-site.
- Narrowed down when and where the vandalism occurred.
- Delegated the follow-up to a supervisor, who reported the employee’s admission.
That was enough to establish a reasonable belief that the employee had defaced company property.
The employee tried to show pretext by pointing to a coworker who once spray-painted graffiti inside a forklift and received a short suspension. But the court found that situation wasn’t comparable. The forklift graffiti stayed in-house; the truss graffiti was visible to customers and hurt the company’s reputation. Different severity, different outcome.
His timing argument also failed. Although the employee visited the company clinic for knee pain on the day he was fired, the manager had already decided to terminate him earlier that morning. The court noted that once an employer has already decided to take an adverse action, a later request for medical care cannot retroactively make that decision retaliatory. Timing alone cannot prove retaliation, and the two-year-old knee injury could not support a discrimination claim.
Employer takeaways
- Reasonableness beats perfection. The Sixth Circuit applied the “reasonably informed and considered” standard, but most courts look for the same thing in substance: a good-faith decision based on specific facts, not speculation.
- Focus on facts, not formalities. Identify who did what, when, and how you know it. Document the basis for your decision.
- Match the depth of the investigation to the uncertainty. When facts are straightforward, confirm them and act. When accounts differ, take the extra step to verify before deciding.
- Make sure timing makes sense. Here, the manager decided to terminate before the employee sought medical care, which defeated the retaliation claim.
- Be consistent and decisive. Once the facts support termination, act promptly and apply the same standards you would in any other case.
Informed judgment wins
The Sixth Circuit didn’t praise this employer for running a perfect investigation; it praised it for running a reasonable one. The plant manager relied on specific facts, acted promptly, and documented his reasoning. That was enough. For employers, that’s the real lesson: informed judgment, not flawless procedure, is what wins in court.
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