## Facts

- Vincent Staub, an angiography technologist at Proctor Hospital, also served in the U.S. Army Reserve, requiring periodic training and drills.
- Staub’s immediate supervisor, Janice Mulally, and Mulally’s supervisor, Michael Korenchuk, were hostile to Staub’s military obligations and criticized or penalized his absences for service.
- Mulally issued Staub a “Corrective Action” disciplinary warning requiring additional reporting and restricting time away from his work area; Staub claimed the grounds were fabricated or exaggerated due to antimilitary animus.
- Korenchuk later reported to Linda Buck, the hospital’s Vice President of Human Resources, that Staub violated the Corrective Action by leaving his desk without notice.
- Buck reviewed Staub’s personnel file, including the Corrective Action and the alleged violation, and decided to terminate Staub.
- Staub grieved the termination, asserting the discipline was motivated by hostility to his Reserve service, but Buck maintained the discharge decision.
- Staub sued under USERRA, alleging his military obligations were a motivating factor in his termination under a “cat’s paw” theory (biased supervisors influenced an otherwise unbiased decisionmaker).

## Issues

1. Whether USERRA permits employer liability when a supervisor without final decisionmaking authority acts with antimilitary animus, intends to cause an adverse action, and influences the ultimate decisionmaker who executes the adverse action.
2. Whether an employer avoids liability when the ultimate decisionmaker reviews the file or conducts an investigation before acting.

## Decision

- The Supreme Court reversed the Seventh Circuit and reinstated the jury verdict for Staub.
- The Court held that an employer is liable under USERRA if a supervisor performs an act motivated by antimilitary animus, intends that act to cause an adverse employment action, and the act is a proximate cause of the ultimate employment action.
- The Court rejected the Seventh Circuit’s requirement that the biased supervisor exert “singular influence” over the final decisionmaker.
- The Court held that an employer is not automatically insulated by an independent investigation; liability may remain if the decision relies on information supplied by the biased supervisor.
- Justice Alito (joined by Justice Thomas) concurred in the judgment, favoring a narrower approach focused on rubberstamping or failure to investigate after notice of possible bias.

## Legal Principles

- USERRA imposes liability when military status is “a motivating factor” in an adverse employment action; the discriminatory intent need not be held by the final decisionmaker alone.
- “Cat’s paw” liability under USERRA applies when: (1) a supervisor acts with discriminatory animus, (2) intends to cause an adverse employment action, and (3) the act is a proximate cause of the ultimate action.
- Proximate cause may be established even when the final decisionmaker exercises some judgment, so long as the biased act remains a causal link to the adverse action.
- An independent investigation can sever causation only if it results in an adverse action for reasons unrelated to the supervisor’s biased act; reliance on biased inputs can preserve causation.

## Conclusion

The Court held that USERRA allows liability based on a supervisor’s discriminatory acts when those acts are intended to bring about, and proximately cause, an adverse employment decision, even if the official who makes the final decision lacks discriminatory animus.


Staub v. Proctor Hosp., 562 U.S. 411 (2011)