Footnote 62

Other cases of mine have also featured workers criticized as non-team players. In one of these, again a complaint based on age, the young, new owner of a family firm--his father, the founder, had recently retired--faulted a long-term employee, a man in his sixties, for "slipping out" before an after-hours party for a co-worker, conduct the boss considered "bizarre." The employee explained that his wife and four-year old son had been waiting for him and he had been compelled to leave because the boy was "acting up." The employer also expressed annoyance that the employee had failed to attend a company outing at Yankee Stadium. A recent United States Court of Appeals decision upheld a grant of summary judgment against a discharged employee criticized for, among other things, not being "a team player." Koski v. Standex Int'l Corp., 307 F.3d 672, 674 (7th Cir. 2002).