Shazor v. Prof'l Transit Mgmt., Ltd., No. 13-3253 (6th Cir. 2014)
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PTM provided the services of a CEO to the Southwest Ohio Regional Transit Authority (SORTA) to control daily operations, while ultimate management authority remained with SORTA’s Board of Trustees. PTM hired Plaintiff as SORTA’s Chief Operating Officer. Plaintiff, an African American woman, a graduate of West Point and University of Michigan Business School, had no prior industry experience. Two years later, PTM changed hands and Plaintiff became CEO on an at-will basis. Within months, PTM began questioning her allegiance to PTM. Plaintiff repeatedly declined to participate in PTM programs. Tensions escalated during negotiations for renewal of PTM’s management contract, which prohibited PTM employees from working for SORTA within a year of its expiration. Plaintiff’s PTM contract contained the same prohibition. PTM suspected that Plaintiff and SORTA were conspiring to have SORTA hire Plaintiff directly. The contract was extended and the one-year hiring prohibition was removed from the contracts. PTM executives continued to regard Plaintiff as a “prima donna” and exchanged several emails critical of Plaintiff. Following a dispute concerning unionization of SORTA workers, PTM fired Plaintiff, purportedly for lying about the dispute. The district court rejected Plaintiff’s discrimination action under Title VII of the Civil Rights Act, 42 U.S.C. 2000e. The Sixth Circuit reversed and remanded, finding PTM’s investigation inadequate to establish that Plaintiff lied.
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