David A. Gauthier v. Keurig Green Mountain, Inc. F/K/A Green Mountain Coffee Roasters, Inc.

Summary

The Supreme Court of Vermont affirmed summary judgment for Green Mountain on Gauthier's workers' compensation retaliation claim and affirmed the denial of his motion to amend. Although Gauthier made a prima facie case through temporal proximity between his benefits claim and his termination, he failed to show the company's internet-policy reason was pretextual; the court adopted the Seventh Circuit's 'honest belief' rule, holding an employer need only honestly believe its proffered legitimate, nondiscriminatory reason rather than prove reasonable reliance on particularized facts. The Court also struck printed-case materials never filed in the trial court and found no abuse of discretion in denying the amendment, which lacked good cause nearly a year into litigation. No separate writings.