6th Circuit Reinstates Racial Discrimination Claim
The 6th Circuit Court of Appeals found that there was enough evidence for the Plaintiff to continue with his civil-rights lawsuit:
Issues: Whether the plaintiff established a prima facie case of race discrimination under Title VII; 42 USC §§ 2000e-2000e-17; Johnson v. Kroger Co.; McDonnell Douglas Corp. v. Green; Texas Dep't of Cmty. Affairs v. Burdine; Laster v. City of Kalamazoo; Whether there was another "similarly situated employee" who was treated more favorably;Ercegovich v. Goodyear Tire & Rubber Co.; Whether the defendant-employer's proffered explanations for its adverse employment decisions were "pretexts" for racial discrimination; Loyd v. St. Joseph Mercy Oakland; Wexler v. White's Fine Furniture, Inc.
Court: U.S. Court of Appeals Sixth Circuit
Case Name: Wheat v. Fifth Third Bank
e-Journal Number: 59872
Judge(s): Daughtrey, Moore, and Clay
The court reversed the district court's grant of summary judgment to the defendant-employer, holding that plaintiff-Wheat established his prima facie case of racial discrimination and raised genuine issues of material fact whether the defendant's stated reasons for firing him were pretextual. Defendant fired plaintiff, an African-American, after he was involved in an altercation at work. The district court dismissed his Title VII and Ohio state-law claims after concluding that he had failed to establish hisprima facie case and to show that defendant's stated reasons for firing him were pretextual. Applying the McDonnell Douglas "burden-shifting" analysis to the plaintiff's Title VII claim, the court reversed. The defendant argued that Wheat failed to establish aprima facie case of discrimination where he was unable to "point to another similarly situated individual" in defendant's employ "who was treated more favorably than he was." However, the court concluded that it appeared Wheat and H, the other individual involved in the altercation, actually performed "different aspects of the same functional job[,]" and there remained a dispute as to which individual was the actual "aggressor" in their confrontation. The court found that defendant articulated non-discriminatory reason for firing Wheat - failure to cooperate during the interview, what were perceived as his "veiled threats" toward H, and its claim that because Wheat was the initial aggressor there was a fear of future violence. However, "[a] jury could reasonably conclude that each of the rationales proposed by the defendant for its decision to fire Wheat either had no basis in fact, did not actually motivate the defendant's decision, or was insufficient to warrant the challenged conduct." Thus, Wheat "established doubt as to the legitimacy of the defendant's explanations and raised the specter that those rationales were merely pretextual." Reversed and remanded.