Supervisor bias? Even accurate reports won't protect you now
Sixth Circuit revives ADA-retaliation claim over selective timekeeping scrutiny; ruling sends clear signal to HR: investigate for bias, not just misconduct.
A routine timecard audit at State Farm turned into a cautionary tale for HR departments everywhere. On Nov. 20, 2025, the U.S. Court of Appeals for the Sixth Circuit reversed summary judgment in an ADA retaliation case and sent it back to trial, ruling that a jury could reasonably conclude a supervisor's selective scrutiny helped trigger an employee's termination.
The case centers on Monica Gray, a 15-year claim specialist who had helped a coworker secure an overtime accommodation under the ADA. After the coworker filed an EEOC charge – with Gray's encouragement – things shifted. When Gray's regular manager took vacation, a fill-in supervisor named Joe Kyle took a closer look at Gray's timesheets. He compared her manual time entries to computer activity logs, spotted discrepancies, and flagged them to HR as potential falsification.
HR then ran a fuller investigation. Investigators pulled building access records, cross-referenced computer activity, and found more mismatches than Kyle's initial report had surfaced. Some entries showed Gray claiming to work when badge records indicated she wasn't in the building. State Farm fired her.
Gray sued for retaliation, arguing Kyle had singled her out. She claimed that similar timekeeping issues existed among other...
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