42 U.S.C. § 2000e-2
Unlawful employment practices: the cases that interpreted this section
17,966 citing cases reviewed of 23,155 in the citation index: 12,593 interpreted the section (annotated below), 5,373 cited it only in passing. Cases filed after 2026-01-28 may not have been reviewed yet.
Have a situation under 42 U.S.C. § 2000e-2?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Race discrimination
Section 2000e-2(a)(1) allows a race discrimination claim to proceed to trial when evidence of discriminatory comments and disputed reasons for termination raises genuine issues of material fact.
Rexach v. University of Connecticut, Department of Dining Services · filed 2004-03-31(a)(1)
The Court concludes that there are genuine issues of material fact regarding at least the following: Mr. Rexach’s purported work performance; the role of the loans in the University’s decision to discharge Mr. Rexach; Mr. Gally’s alleged discriminatory conduct and derogatory statements to Mr. Rexach and other Latinos, but not to non-Latinos; and the University’s alleged failure to address Mr. Gally’s conduct despite Mr. Rexach’s complaints to management about Mr. Gaily. All of these issues of fact render summary judgment inappropriate at this stage.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits refusing to hire someone because of race, including when the applicant and the decisionmakers are white.
Clements v. Barden Mississippi Gaming, L.L.C. · filed 2004-05-07(a)(1)
The statute does not say nor should it be interpreted to apply to some races and not to others, or to apply only when certain races racially discriminate against other races but not others.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of the employee’s own race, not a third party’s race.
Swanson v. City of Bruce · filed 2004-07-01(a)(1)
That is, the person who is discharged must be discharged on account of his race, not on account of any third party’s race.Read the full opinion on CourtListener →
Section 2000e-2(a) requires facts supporting a claim that an employee was treated less favorably because of race; conclusory allegations are insufficient.
Luy v. Baltimore Police Department · filed 2004-07-16(a)
Luy’s conclusory allegations of race discrimination, devoid of any reference to actual events during his employment, are not sufficient to state a claim under Title VII or § 1981 for race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a plaintiff must present enough evidence of discrimination to survive summary judgment.
Jones v. Yonkers Public Schools · filed 2004-07-21(a)(1)
We conclude that plaintiff has not introduced sufficient evidence of racial discrimination to create a question of material fact for the jury and defeat summary judgment.Read the full opinion on CourtListener →
Adding a candidate to an interview pool can be circumstantial evidence of race discrimination when considered with the surrounding facts.
Rudin, Janine v. Lincoln Land Communi · filed 2005-08-25(a)(1)
We think that the addition of Hudson into the interview pool, when considered with the other facts and circum- stances of this case, constitutes circumstantial evidence of racial discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim to proceed to trial when the evidence could allow a reasonable jury to find that the employer acted because of the plaintiff’s race.
Cornwell v. Electra Central Credit Union · filed 2006-02-28(a)(1)
In the context of employment discrimination law under Title VII, summary judgment is not appropriate if, based on the evidence in the record, a reasonable jury could conclude by a preponderance of the evidence that the defendant undertook the challenged employment action because of the plaintiff’s race.Read the full opinion on CourtListener →
For a race-based pay discrimination claim under § 2000e-2(a)(1), differences in job responsibilities and relevant experience can show that employees are not similarly situated.
Hatchett v. Health Care & Retirement Corp. of America · filed 2006-06-01(a)(1)
Under these circumstances, the relevant aspects of Hatchett’s employment are not, as she claims, “nearly identical” to Morse’s employment. Thus Hatchett and Morse are not “similarly situated” employees.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits discharge because of race; when an employer gives a nondiscriminatory reason for discharge, the employee must show that reason is a pretext for discrimination.
Hampton v. City of South Miami · filed 2006-07-25(a)
Title VII makes it unlawful for an employer “to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a). ... After our own careful review of the record, we can find no error in the district court’s analysis and conclusion that Hampton did not satisfy his burden at the third step of the McDonnell Douglas inquiry.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment, which a plaintiff may prove through the indirect burden-shifting method.
Ferguson v. Medical College of Wisconsin · filed 2007-01-09(a)(1)
Thus, Ferguson must proceed under the indirect burden-shifting method of proof.Read the full opinion on CourtListener →
Race discrimination claims under this section use the same framework as parallel equal protection claims brought under § 1983.
Keaton v. Cobb County · filed 2007-02-19(a)(1)
As a result, this Court uses the same framework to evaluate Title VII claims and Equal Protection race discrimination claims brought under § 1983.Read the full opinion on CourtListener →
A racial-discharge claim based on circumstantial evidence follows the McDonnell Douglas burden-shifting framework, under which the employee may show that the employer's stated reason is pretextual.
Officer v. Sedgwick County · filed 2007-02-27(a)(1)
Title VII provides a cause of action to employees who suffer an adverse employment action because of their race, color, religion, sex, or national origin. See 42 U.S.C. § 2000e-2(a)(1). Because M s. Officer seeks to prove her Title VII claim s solely through indirect or circumstantial evidence of racial animus, we examine her claim under the burden-shifting framework established by M cDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-04 (1973).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits race discrimination claims based on a hostile work environment and disparate treatment to proceed when the evidence creates a genuine dispute about harassment, intentional discrimination, and pretext.
Williams v. Pennsylvania State Police · filed 2007-03-13(a)(1)
We conclude that Williams has adduced evidence sufficient to create a genuine issue of material fact as to whether the he was subjected to a racially hostile work environment as well as intentional discrimination; defendant’s proffered reasons for his transfers are arguably pretextual.Read the full opinion on CourtListener →
A Title VII plaintiff alleging race discrimination must show that she met her employer’s legitimate performance expectations and that similarly situated employees outside her protected class were treated more favorably.
Fane, Marcella v. Locke Reynolds, LLP · filed 2007-03-14(a)(1)
To successfully set forth a prima facie case of racial discrimination, Fane must show that: 1) she is a member of a protected class; 2) she was meeting her employer’s legitimate performance expectations; 3) she suffered an adverse employment action; and 4) other similarly situated employees who were not members of the protected class were treated more favorably.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to proceed when evidence of different treatment of similarly situated employees creates a triable issue of fact.
Fields v. Riverside Cement Co. · filed 2007-03-27(a)(1)
Fields has adduced sufficient evidence to create a triable issue of fact regarding RCC’s dissimilar treatment of similarly situated non-black employees, the only element of his prima facie case RCC challenged.Read the full opinion on CourtListener →
Under Section 2000e-2(a)(1), a race discrimination plaintiff using the indirect method must show satisfactory job performance and more favorable treatment of similarly situated employees.
Alexander v. Biomerieux, Inc. · filed 2007-04-30(a)(1)
The court finds that Alexander has not established a prima facie case of racial discrimination under Title VII or the ADEA. Alexander, an African-American, is a member of a protected class. However, Alexander cannot establish that she had performed her job in a satisfactory manner, or that similarly situated employees were treated more favorably than herself.Read the full opinion on CourtListener →
A race-discrimination claim based on a denied accommodation requires evidence from which a reasonable jury could find that race motivated the denial; white coworkers who are not similarly situated do not establish that claim.
Moody v. Cook County · filed 2007-06-01(a)(1)
LaFrey and Graves, however, are not similarly situated with Plaintiff. ... Ultimately, Plaintiffs scant evidence of discrimination is not sufficient to create a genuine issue of material fact that the County failed to accommodate his disability because of his race.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2 requires facts supporting an inference that an adverse employment action occurred because of race.
Mutts v. Southern Connecticut State University · filed 2007-06-15
Although Mutts describes negative comments made by her supervisor, Mutts does not indicate that these comments were racially derogatory and nothing in the record gives rise to the inference that any alleged adverse employment action was “because of’ her family’s race.Read the full opinion on CourtListener →
Under § 2000e-2(a), a race discrimination claim fails when the employer gives a legitimate reason for a transfer and the employee offers no evidence of pretext or that race was a motivating factor.
Broussard v. TX Dept Cr Justice · filed 2007-07-19(a)
Title VII prohibits employers from discriminating against employees on the basis of race. 42 U.S.C. § 2000e-2(a). ... Broussard has not put forth any evidence that TDCJ’s reason was pretext or that if it was true, race was a motivating factor. Accordingly, the district court did not err in granting the defendants summary judgment on Broussard’s discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a plaintiff alleging race-based discharge through circumstantial evidence to show facts supporting an inference of discriminatory motive.
Muldrow v. Department of Defense · filed 2008-02-13(a)(1)
Plaintiff, however, has failed to allege sufficient facts showing an inference of discriminatory motivation. Plaintiff offers no evidence that give rise to an inference that his supervisor was motivated to fire him because of his race.Read the full opinion on CourtListener →
A Title VII race discrimination claim survives summary judgment when the evidence raises a genuine dispute over whether the employer’s stated reason for eliminating a position was its actual reason.
Tratree v. BP North American Pipelines, Inc. · filed 2008-05-02(a)(1)
Tratree has therefore presented genuine issues of material fact as to whether BP’s proffered explanation is the actual reason it eliminated his position rather than Williams’s.Read the full opinion on CourtListener →
Section 2000e-2 allows a race discrimination claim to proceed when a jury could find that the employer’s stated reason was pretextual and employees of another race were treated more favorably.
Williams v. Wells Fargo Financial Acceptance · filed 2008-07-03
There is sufficient evidence from which a reasonable juror could infer that the reasons given by Wells Fargo for firing him were pretextual and non-African-American employees were treated more favorably.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination in the terms and conditions of employment, and a claim requires proof of discriminatory intent.
Crayton v. Alabama Department of Agriculture & Industries · filed 2008-12-18(a)
Title VII prohibits an employer from discriminating “against any individual with respect to his compensation, terms, conditions, or privileges of employment because of such individual’s race, color, religion, sex or national origin.” 42 U.S.C. § 2000e-2(a). The critical element in establishing wrongful discrimination in violation of Title VII is discriminatory intent.Read the full opinion on CourtListener →
A Title VII race discrimination claim under § 2000e-2(m) uses the same elements as a § 1981 claim.
Howard v. JACOBS ENGINEERING, INC. · filed 2008-11-12(m)
The elements of Section 1981 claims, 42 U.S.C. § 1981, and Title VII, 42 U.S.C. § 2000e-2(m), are identical, and will be analyzed together.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that an adverse employment action occurred under circumstances supporting an inference of race discrimination.
Martin v. MTA Bridges & Tunnels · filed 2009-04-03(a)(1)
On the record before the Court, plaintiff fails to raise any triable issue of fact on the issue of race discrimination. Defendant has submitted uncontroverted evidence that plaintiffs job title was not changed to “Manager” because of factors having nothing to do with race.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a plaintiff challenging a refused transfer as race discrimination to show less favorable treatment than similarly situated employees and, if the employer gives a legitimate reason, that the reason was pretext.
Brantley v. Muscogee County School Dist. · filed 2009-04-13(a)
Although Brantley has preserved his claim regarding his post-November 28, 2004, requests to transfer back into his original masonry position, the district court correctly granted MCSD’s motion for summary judgment on this claim, because (1) Brantley failed to establish he was treated less favorably than similarly-situated white employees, (2) MCSD offered a legitimate, non-discriminatory reason for its actions, and (3) Brantley failed to show this reason was pretext.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) can cover race-based requirements that an employee use a separate entrance and restrooms from white employees.
Bell v. FL Highway Patrol · filed 2009-04-15(a)(1)
She also provided a short and plain statement of her discrimination claims -- she was required to enter through a separate entryway and to use separate restrooms than white employees -- that, if proved, could entitle her to relief under Title VII.Read the full opinion on CourtListener →
Section 2000e-2 prohibits an employer from taking an adverse employment action because of an employee’s race.
Harris v. City of Fresno · filed 2009-05-26(a)(1)
Federal law prohibits an employer from taking an adverse employment action against an employee because of his or her race.Read the full opinion on CourtListener →
A claim that an employer denied pay raises because of race requires proof of intentional race discrimination.
Littleton v. Pilot Travel Centers, LLC · filed 2009-06-04(a)
In any event, the assertions are tangential to our limited role on appeal, which is to determine whether the district court’s specific factual findings, and particularly its ultimate finding that Littleton failed to prove intentional race discrimination, are clearly erroneous. Having carefully reviewed the trial record, “[w]e cannot say that a trier of fact could only reach the conclusion that [Pilot] was motivated by race ... prejudice, and we cannot reverse unless we can say that.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from discharging an employee because of race.
Odom v. International Paper Co. · filed 2009-08-31(a)(1)
Title VII makes it “an unlawful employment practice for an employer ... to discharge or otherwise discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race.” 42 U.S.C. § 2000e-2(a)(1).Read the full opinion on CourtListener →
Section 2000e-2(a) allows a race discrimination claim to proceed when evidence raises genuine factual disputes about the employee’s performance and termination.
Equal Employment Opportunity Commission v. Memphis Goodwill Industries Inc. · filed 2009-12-22(a)
The Court finds, however, that the evidence presented by Plaintiff and Defendant leads to genuine issues of material fact as to Ms. Mister’s performance on the job prior to her “write ups” and termination. Because material issues of fact exist, summary judgment is not appropriate. Accordingly, Defendant’s motion for summary judgment with respect to Plaintiffs racial discrimination claim is DENIED.Read the full opinion on CourtListener →
An employer’s benign motive does not excuse an adverse employment action taken because of an employee’s race.
Bouknight v. D.C. Fire and Ems Department · filed 2010-01-15(a)(1)
Thus, even if Captain Tompkins acted from a benign motive, that fact would not diminish the defendant’s liability under Title VII’s disparate treatment provisions.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employers from discriminating in compensation or other terms of employment because of race.
Moore v. Potter · filed 2010-03-29(a)(1)
It is unlawful under Title VII for an employer to “discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race.” 42 U.S.C. § 2000e-2(a)(l).Read the full opinion on CourtListener →
A race discrimination complaint under § 2000e-2(a) must allege facts making it plausible that race caused the adverse employment action.
Coleman v. Maryland Court of Appeals · filed 2010-11-10(a)
However, the complaint fails to establish a plausible basis for believing Broccolina and Coleman were actually similarly situated or that race was the true basis for Coleman’s termination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that an adverse employment action was motivated by race; unfair treatment alone does not establish discrimination.
Pridgen v. GREEN VALLEY SNF LLC · filed 2010-12-21(a)(1)
At most, Pridgen may have a claim that she, herself, was unfairly treated, but the record belies the notion that any unfair treatment targeted toward her was grounded in racial animus.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race or color discrimination plaintiff to prove an adverse employment action caused by race or color.
Hampton v. Conner · filed 2011-01-13(a)(1)
The “two essential elements” of a discrimination claim under this section are “that (i) plaintiff suffered an adverse employment action (ii) because of the race [or] color” Baloch v. Kempthorne, 550 F.3d 1191, 1196 (D.C. Cir. 2008).Read the full opinion on CourtListener →
Race can be a motivating factor in an unlawful discharge, and statements linking the firings to race can be direct evidence sufficient to defeat summary judgment.
Andrews v. FANTASY HOUSE, INC. · filed 2011-03-03(m)
As a result, a jury could believe that Baker told Wall that Fantasy Gifts was going to terminate Andrews because it was afraid she would “pull the race card” and that it needed to fire Wall because she is white in order to cover up its racial grounds for terminating Andrews. Such statements are direct evidence of race discrimination.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) requires evidence supporting a reasonable inference that the employer's action was motivated by race.
Desir v. Board of Cooperative Educational Services · filed 2011-03-29(a)(1)
Taking all of it together in the light most favorable to Plaintiff, Desir has failed to establish an inference of discrimination sufficient to support a claim of discrimination.Read the full opinion on CourtListener →
Section 2000e-2 race discrimination claims based on circumstantial evidence follow the McDonnell Douglas burden shifting framework.
Dickerson v. United States Deparment of Veterans Affairs · filed 2011-03-31(a)(1)
Claims of racial discrimination based on circumstantial evidence are evaluated under the burden shifting framework developed in McDonnell Douglas v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). ... Defendants have failed to raise a proper basis for granting summary judgment on Dickerson’s race discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a) bars race discrimination in employment; an employee who cannot rebut an employer’s race-neutral reason for termination cannot prevail on that claim.
Young v. School District of Philadelphi · filed 2011-05-11(a)
We agree with the District Court’s conclusion that Young’s evidence could not overcome the school district’s race-neutral reason for his termination.Read the full opinion on CourtListener →
A race discrimination claimant must present evidence that comparable employees outside the protected class were treated more favorably or that the adverse action otherwise supports an inference of discrimination.
Livingston v. Borough of Edgewood · filed 2011-06-02(a)(1)
In this case, Livingston has failed to meet his initial burden to establish a prima facie case of unlawful discrimination by a preponderance of the evidence in regard to the ... fourth element of his racial discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employment discrimination based on race or sex.
Klute v. Shinseki · filed 2011-07-12(a)(1)
Title VII prohibits discrimination on the basis of race and sex, among other categories. ... The Complaint does not, however, contain facts supporting either the race or sex discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination in employment, and a claim may proceed when the alleged facts plausibly show less favorable treatment than similarly situated employees outside the protected class.
McCallum v. Billy Graham Evangelistic Ass'n · filed 2011-08-05(a)
Title VII of the Civil Rights Act of 1964 prohibits an employer from “discharg[ing] any individual, or otherwise ... discriminat[ing] against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race.” 42 U.S.C.A. § 2000e-2(a). ... Viewing the facts in the light most favorable to McCallum, the Court finds Plaintiffs claim of racial discrimination sufficiently plausible to go forward at this stage.Read the full opinion on CourtListener →
When an employer gives a nondiscriminatory reason for firing an employee, a race discrimination plaintiff must offer enough evidence for a reasonable jury to find that reason was pretextual and the employer intentionally discriminated.
Hodge v. United Airlines · filed 2011-10-21(a)(1)
Because United has asserted a legitimate nondiscriminatory reason for firing Hodge, the Court must determine whether Hodge has “produced sufficient evidence for a reasonable jury to find that the employer’s asserted non-discriminatory reason was not the actual reason and that the employer intentionally discriminated against [him] on the basis of race.” Brady, 520 F.3d at 494.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a race-discrimination plaintiff to show an adverse employment action because of race.
Kelly v. Lahood · filed 2012-01-12(a)
To survive summary judgment on each of these claims, Kelly must provide sufficient evidence for a reasonable jury to determine that 1) he suffered an adverse employment action 2) because of his race or his protected activity.Read the full opinion on CourtListener →
A race-based refusal-to-hire claim under § 2000e-2(a)(1) fails when the plaintiff cannot show that the employer’s stated nondiscriminatory reason was pretextual.
Brown v. Unified School District No. 501 · filed 2012-02-01(a)(1)
We conclude that Mr. Brown failed to establish that the School District’s proffered legitimate, nondiscriminatory reasons for refusing to rehire him were pretextual.Read the full opinion on CourtListener →
A race discrimination complaint under § 2000e-2(a) must allege more favorable treatment of similarly situated employees; a conclusory allegation of discrimination does not suffice.
Williams v. Recovery School District · filed 2012-03-15(a)
Aside from these allegations, and assuming that he was qualified for this position, at no point does Williams allege that others similarly situated were more favorably treated. ... Accordingly, the Court finds that Williams fails to state a claim and his Title VII claim for race discrimination must be dismissed.Read the full opinion on CourtListener →
Section 2000e-2 prohibits race discrimination affecting an employee’s compensation, employment opportunities, or employment status.
Davis v. Dunn Construction Co. · filed 2012-05-24(a)(2)
Title VII prohibits discrimination against an employee by the employer on the basis of race “with respect to [ ] compensation, terms, conditions, or privileges of employment,” and discriminatory practices that would “deprive any individual of employment opportunities or otherwise adversely affect his status as an employee....” 42 U.S.C. § 2000e-2(a)(2). ... After a careful review of the record and the arguments made in this case, the court concludes that the record evidence is insufficient for Plaintiff to establish any of his claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race-based termination claim to reach a jury when the employee presents sufficient evidence that the employer’s stated reason for firing him was pretextual.
Freeman v. Perdue Farms Inc. · filed 2012-11-09(a)(1)
Because Mr. Freeman produced sufficient evidence of pretext with respect to his claims for retaliation and termination based on race in violation of Title VII, the district court erred in granting Perdue summary judgment on those claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; an employee’s unequivocal concession that race had nothing to do with her termination supports summary judgment on that claim.
Ross v. Jefferson County Department of Health · filed 2012-11-15(a)(1)
Under Title VII, it is unlawful for an employer “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). ... When asked during her deposition whether she “[felt] like [her] termination had anything to do [with] . . . [her] race,” Ross responded, “no.” Based on Ross’s unequivocal concession, the district court was entitled to grant summary judgment in favor of the Health Department.Read the full opinion on CourtListener →
Section 2000e-2(a) requires evidence of race-based discrimination; disagreement with an employee and criticism without a racial connection do not, by themselves, establish it.
Brown v. Advocate South Suburban Hospital · filed 2012-11-21(a)
But the fact that someone disagrees with you (or declines to take your advice) does not, without more, suggest that they discriminated against you. Nor do any of the criticisms that the plaintiffs experienced suggest a discriminatory motive. All of the criticisms used non- racial language, and nothing else about their context suggests that they were racially motivated.Read the full opinion on CourtListener →
Section 2000e-2(a) allows a race discrimination claim to reach a jury when the evidence could show that race motivated an employee’s termination.
Kwon v. University of Vermont & State Agricultural College · filed 2012-12-07(a)
Because this Court believes that a reasonable jury could conclude that Kwon was discriminated against on the basis of race, summary judgment on the race discrimination claim is denied.Read the full opinion on CourtListener →
When an employer gives a legitimate, nondiscriminatory reason for discharge, a race discrimination plaintiff must show that the reason was pretextual.
Holmes v. State of Georgia · filed 2013-01-15(a)(1)
Even if Holmes could establish a prima facie case of race discrimination, the DOC presented a legitimate, nondiscriminatory reason for its action, and Holmes presented no evidence to show that such reason was pretextual.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; an employer’s legitimate reason defeats a circumstantial discrimination claim when the employee offers no evidence that the reason is pretextual.
Holmes v. Georgia ex rel. Strickland · filed 2013-01-15(a)(1)
Even if Holmes could establish a prima facie case of race discrimination, the DOC presented a legitimate, nondiscriminatory reason for its action, and Holmes presented no evidence to show that such reason was pretextual.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits employers from disadvantaging employees in compensation, employment terms, or opportunities because of race.
Alers v. City of Philadelphia · filed 2013-01-24(a)
Title VII’s anti-discrimination provision makes it unlawful for an employer to discriminate against any individual with respect to “compensation, terms, conditions, or privileges of employment” or to “deprive any individual of employment opportunities or otherwise adversely affect his status as an employee” because of such individual’s race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not treat discrimination based on an employee’s alleged racism as discrimination based on the employee’s race.
Maraschiello v. City of Buffalo Police Department · filed 2013-02-27(a)(1)
“Racism” is not a race, and discrimination on the basis of alleged racism is not the same as discrimination on the basis of race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence supporting an inference of intentional race discrimination; a similarly situated comparator is one way to provide it.
Thompson v. Tyson Foods, Inc. · filed 2013-03-29(a)(1)
Without a similarly situated comparator or any other sufficient evidence to support an inference of intentional discrimination, Plaintiff has failed to establish his claim of racial discrimination, and Defendant is entitled to judgment as a matter of law.Read the full opinion on CourtListener →
An employee singled out for poor treatment must link that treatment to race to support an inference of intentional discrimination.
Sherena Turner v. Florida Prepaid College Board · filed 2013-07-02(a)(1)
Unless something links the actions to the employee’s race, that a decisionmaker singles an employee out does not permit a jury to infer intentional discrimination based on race.Read the full opinion on CourtListener →
A race discrimination claim survives summary judgment when the evidence permits a factfinder to conclude that the employer took an adverse action because of the employee’s race.
Morgan v. SVT, LLC · filed 2013-08-01(a)
The plaintiff’s task in opposing a motion for summary judgment is straightforward: he must produce enough evidence, whether direct or circumstantial, to permit ... the trier of fact to find that his employer took an adverse action against him because of his race.Read the full opinion on CourtListener →
A race discrimination claimant proceeding under the McDonnell Douglas framework must show that similarly situated employees were treated more favorably and that the employer’s stated reasons were pretextual.
McFarlin v. State Board of Technical and Adult Education · filed 2013-08-06(a)(1)
McFarlin failed to establish a prima facie case that her placement on “leave” was based on racial discrimination, as she failed to show sufficiently that similarly situated employees were treated more favorably than she. Even if she had established a prima facie case, McFarlin did not carry her burden to show sufficiently that the proffered nondiscriminatory reasons for her placement on leave, including her perceived insubordination, were mere pretexts.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence connecting an adverse employment action to race to prove race discrimination under the direct method.
Strong v. Delaware County · filed 2013-09-30(a)(1)
While it is certainly rude, the comment itself relates to Mr. Strong’s purported skills as a building commissioner and is not in any way related to race. Therefore, the Court finds that Mr. Strong’s discrimination claims fail under the direct method of proof.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence connecting an adverse employment action to race; a general assertion of harsher treatment is insufficient.
Akerson v. Pritzker · filed 2013-11-04(a)(1)
Though she asserts generally that she was treated more harshly than non-Caucasian employees when she was terminated, she does not point to evidence that would permit a reasonable jury to infer that her termination had anything to do with being Caucasian.Read the full opinion on CourtListener →
Section 2000e-2 requires an alleged racially charged incident to be contemporaneous with or causally related to an adverse employment action for it to support an inference of discrimination.
Lumpkins-Benford v. Allstate Insurance · filed 2013-11-05
If the action was intended as a statement on Plaintiffs race, as she contends, it is not probative of discrimination unless it was contemporaneous with or causally related to the adverse action.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) protects against discrimination based on race and sex together; equal treatment of white women and African American men does not defeat a prima facie claim by an African American woman.
Shazor v. Professional Transit Management, Ltd. · filed 2014-02-19(a)(1)
If a female African American plaintiff (for example) establishes a sufficient foundation of discrimination, a defendant cannot undermine her prima facie case by showing that white women and African American men received the same treatment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not treat a ban on dreadlocks as intentional race discrimination because a hairstyle is a mutable characteristic, even when closely associated with a racial group.
Equal Employment Opportunity Commission v. Catastrophe Management Solutions · filed 2014-03-27(a)(1)
Title VII prohibits discrimination on the basis of immutable characteristics, such as race, sex, color, or national origin. A hairstyle, even one more closely associated with a particular ethnic group, is a mutable characteristic. Therefore, the Complaint fails to state a plausible claims for relief.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) must allege facts connecting the employer’s action to the employee’s race.
Slate v. Public Defender Service for the District of Columbia · filed 2014-04-02(a)(1)
Second, even if the plaintiff had identified his race, his claim would still fail because he has failed to plead that he was suspended and terminated because of his race.Read the full opinion on CourtListener →
A Title VII race discrimination claim can survive summary judgment when evidence of racial animus and pretext creates a genuine dispute about the reason for termination.
Georgie Brewer v. New Era, Inc. · filed 2014-04-29(a)(1)
Plaintiffs have advanced sufficient evidence to create a material issue of fact concerning whether their race was the reason they were terminated from their jobs rather than the reasons offered by Defendant.Read the full opinion on CourtListener →
Under the McDonnell Douglas framework, a Title VII race discrimination plaintiff must show that a similarly situated employee outside her protected class received more favorable treatment.
McQueen v. Aerotek · filed 2014-07-29(a)(1)
Here, the district court correctly concluded that McQueen could not establish a prima facie case of race discrimination under Title VII against either Aerotek or Wells Fargo. McQueen did not submit any evidence that she was replaced by, or treated less favorably than, a similarly situated employee outside of her protected class.Read the full opinion on CourtListener →
A race discrimination plaintiff relying on comparator evidence must show that the decisionmaker knew of the comparator’s similar misconduct.
Landry v. Lincare, Inc. · filed 2014-08-28(a)(1)
Because Landry has provided no evidence demonstrating Burns was aware of, and consciously overlooked, Sircy’s refusal to deliver oxygen, he has failed to establish a prima facie case of race discrimination based on comparator evidence.Read the full opinion on CourtListener →
Section 2000e-2 treats employment discrimination based on race as distinct from discrimination based on skin color.
Barrella v. Village of Freeport · filed 2014-08-28(a)(1)
However, although courts often confuse the two, both Title VII and the NYSHRL treat claims for race as distinct from claims based on skin color.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that an employer’s stated reason for termination conceals race discrimination.
Johnson v. Perez · filed 2014-09-02(a)(1)
While there may well be a genuine issue of fact regarding whether Defendant’s stated non-discriminatory reasons for terminating Johnson are, in fact, the actual reasons, Johnson has not offered sufficient evidence to support the conclusion that Defendant’s proffered reasons are pretext for race discrimination.Read the full opinion on CourtListener →
Under § 2000e-2(a)(1), a supervisor’s race-related remarks can support a jury’s inference of discrimination even when they are too ambiguous to establish liability as a matter of law.
Henson v. Canon Business Solutions, Inc. · filed 2014-09-24(a)(1)
These statements are sufficient to defeat Canon’s motion for summary judgment because they would allow a reasonable jury to infer a discriminatory motive. However, these isolated and ambiguous statements are not sufficient to support judgment as a matter of law in Henson’s favor.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires workplace harassment or an adverse employment action to be because of the employee’s protected characteristic.
Jacobs v. Biando · filed 2014-11-24(a)(1)
To be actionable under Title VII, the harassing conduct or the adverse employment action must be because of the employee’s protected characteristic, in this case race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a plaintiff relying on indirect evidence must show that the employer’s stated reason for its decision was pretextual.
McNeil v. Greyhound Lines, Inc. · filed 2014-11-25(a)(1)
McNeill’s disparate treatment claim fails because he has produced insufficient evidence to raise a genuine issue of material fact as to whether Greyhound’s legitimate, non-discriminatory reason for terminating him was pretext for race discrimination.Read the full opinion on CourtListener →
A Title VII race discrimination claim cannot survive summary judgment on comparator evidence when the employees’ relevant circumstances materially differ and the employer’s stated reason is not shown to be pretextual.
Sanders v. Metropolitan Police Department · filed 2015-02-10(a)
The Court finds that no reasonable jury could find for plaintiff on the overwhelming evidence differentiating his circumstances from those of the convicted white officer.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that would allow a reasonable inference of discriminatory intent to sustain a race-based disparate-treatment claim.
Hamilton v. Sheridan Healthcorp Inc. · filed 2015-03-03(a)(1)
Dr. Loskove’s statement that he lacked confidence that Dr. Hamilton could be “the face of the department at night” does not support a reasonable inference of discriminatory intent, given the evidence of Dr. Hamilton’s multiple performance issues, which included delaying a life-saving emergency surgery and a post-operative nerve block; failing to comply with various corporate and departmental requirements; numerous instances of failing to complete charts; and lying about his failure to pass a required certification exam.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) supports a race discrimination claim when well-pleaded facts plausibly suggest an adverse employment action caused by intentional racial discrimination; the complaint need not establish a prima facie case.
Surtain v. Hamlin Terrace Foundation · filed 2015-06-16(a)(1)
Accordingly, a court may properly enter default judgment on a claim of racial discrimination when the well-pleaded factual allegations of a complaint plausibly suggest that the plaintiff suffered an adverse employment action due to intentional racial discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race-based discipline, but courts do not review an employer’s disciplinary judgment absent discriminatory treatment.
Schaffhauser v. United Parcel Service, Inc. · filed 2015-07-23(a)(1)
Employee discipline, as long as it is not conducted in a discriminatory fashion, is a business judgment not reviewed by the courts.Read the full opinion on CourtListener →
An employee challenging a promotion or work assignment as race discrimination must show that the employer’s stated legitimate reasons were pretextual.
Archibald v. United Parcel Service Co inc. · filed 2015-08-24(a)
Even if we assume, like the district court, that Archibald established a prima facie case of racial discrimination, he failed to establish that the legitimate reasons proffered by UPS for its decisions were pretextual.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employers from taking adverse employment actions because of an employee’s race.
Toney v. Select Specialty Hospital · filed 2015-10-26(a)(1)
Toney has brought her claims for race discrimination under Title VII and § 1981, both of which prohibit employers from taking adverse employment actions against employees on the basis of race.Read the full opinion on CourtListener →
Section 2000e-2(a) requires an employee relying on circumstantial evidence of race discrimination to rebut each legitimate, nondiscriminatory reason the employer gives for its decision.
Peterson v. Board of Trustees of University · filed 2016-03-02(a)
Peterson failed to present evidence that UAHSF’s proffered nondiscriminatory reasons for firing her were pretextual. UAHSF listed Peterson’s two patient privacy violations as reasons for terminating her, and Peterson admitted to these violations. Nor does Peterson deny that a number of her coworkers complained about her and that she repeatedly met with management to address interpersonal conflicts in the workplace. And Peterson presented no evidence to rebut UAHSF’s assertion that several checks she processed were returned because she had not gotten proper identification. Thus, we affirm the district court’s grant of summary judgment as to Peterson’s Title VII and §§ 1981 and 1983 racial discrimination claims.Read the full opinion on CourtListener →
For a Title VII race discrimination claim, a plaintiff can show that an employer’s stated reason for termination was pretext by presenting evidence that supports an inference of bad faith or discriminatory animus.
Pete Keller, Jr. v. Coastal Bend College · filed 2016-03-22
To show pretext by a preponderance of the evidence, this court requires a plaintiff to present evidence supporting an inference that the employer acted in bad faith or was motivated by discriminatory animus when terminating an employee. ... In conclusion, Keller cannot establish pretext on any of the theories that he puts forth, and thus, his race discrimination claim fails.Read the full opinion on CourtListener →
A race discrimination claim cannot survive summary judgment without evidence that the adverse employment action was racially motivated.
Long v. Alabama Department of Human Resources · filed 2016-05-31(a)(1)
There is, however, no evidence to suggest that Plaintiff’s termination was racially motivated.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim without comparator evidence if other circumstantial evidence raises a factual question about discriminatory intent.
Banks v. Igov Technologies, Inc. · filed 2016-09-28(a)(1)
We recognize that a plaintiff will survive summary judgment even without comparator evidence as long as he presents some other circumstantial evidence that raises a question of fact as to the employer’s discriminatory intent. ... Because Plaintiff has failed to establish a prima facie case of discrimination under McDonnell Douglas, or to produce any other circumstantial evidence of discrimination, summary judgment is warranted on his race discrimination claim.Read the full opinion on CourtListener →
Race must be a motivating factor in a termination to establish a Title VII race discrimination claim.
DeJesus v. WP Company LLC · filed 2016-11-15(m)
To prevail, a plaintiff must demonstrate that race was “a motivating factor” for the termination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; when an employer gives a legitimate nondiscriminatory reason, the employee must show that reason was pretextual.
Dixon v. Board of County Commissioners · filed 2016-11-17(a)(1)
Here, there is simply no evidence that Defendant’s proffered reason for Plaintiffs termination was a pretext for race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim over a firing to proceed when the evidence would permit a jury to find that the employee was fired because of race.
Strahan v. Bowen Center · filed 2017-03-06(a)(1)
A reasonable jury could find on that basis that Ms. Strahan was fired because she is black, so Bowen Center’s motion for summary judgment is denied as to Ms. Strahan’s claim for race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) bars intentional race discrimination in employment and practices that create unjustified barriers to equal opportunity.
Davis v. District of Columbia Child and Family Services Agency,et Al · filed 2017-03-31(a)(1)
The statute therefore bars “both intentional discrimination and artificial, arbitrary, or unnecessary barriers to equal opportunity.”Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination in employment; an employee challenging a stated reason for termination must present evidence from which a reasonable jury could infer discrimination.
Silva v. Cleary Gottlieb Steen & Hamilton, LLP · filed 2017-05-25(a)
Because plaintiff has not come forward with any evidence to support his allegation that defendant’s stated reason for terminating his employment as a temporary attorney was pretext for race discrimination, defendant’s motion for summary judgment will be granted.Read the full opinion on CourtListener →
Unequal training opportunities and departures from written policies may support an inference of race discrimination sufficient to defeat summary judgment under § 2000e-2(a)(1).
Barnes v. Northern Indiana Public Service Co. · filed 2017-07-18(a)(1)
Therefore, a reasonable jury could infer that because of Barnes’ race, he was not afforded the same training opportunities as his Caucasian counterparts so that NIP-SCO could more easily disqualify Barnes from the program.Read the full opinion on CourtListener →
A Title VII race discrimination claim may proceed to trial when evidence of unequal treatment and pretext could support a finding that race caused the employee’s discharge.
McKinney v. Sheriff's Office of Whitley Co · filed 2017-08-08(a)(1)
We reverse. Viewed in the light most favorable to plaintiff McKinney, his extensive evidence adds up to a strong case of race discrimination.Read the full opinion on CourtListener →
A race discrimination plaintiff relying on comparator evidence must show that a similarly situated person outside her protected class received more favorable treatment.
Matthews v. City of Mobile, Alabama · filed 2017-08-16(a)(1)
Because Matthews mounted no evidence of a similarly situated individual outside of her protected class who received more favorable treatment, she failed to establish a prima facie case of race discrimination.Read the full opinion on CourtListener →
A plaintiff alleging race discrimination through circumstantial evidence can establish a prima facie case by showing that a similarly situated employee outside the protected class was treated differently.
Gore v. Jacobs Engineering Group · filed 2017-08-29(a)(1)
Second, Gore failed to establish a prima facie case of discrimination under the McDonnell Douglas framework because he did not identify a similarly situated employee who was not terminated. John Blaha—the only potential comparator Gore points to—was not “nearly identical” to Gore in all relevant respects.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race caused a pay disparity; a higher-paid coworker of another race does not alone establish discrimination.
Golla v. Office of the Chief Judge of Cook County · filed 2017-11-15(a)(1)
In short, the evidence as a whole was insufficient for a reasonable jury to conclude that the Office paid Golla at a lower pay grade than Taylor on account of his race. Therefore, Defendants are entitled to summary judgment.Read the full opinion on CourtListener →
A Title VII race-discrimination plaintiff relying on a coworker as a comparator must show that they were similarly situated in all relevant respects.
Abram v. Von Maur Inc. · filed 2018-01-09(a)(1)
The two were thus neither similarly situated in “all relevant respects” nor did they engage in a “nearly identical” quality and quantity of misconduct.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; a race discrimination claim cannot survive summary judgment without evidence that race caused the discharge.
Johnson v. Candice Jones, Director Illinois Department of Juvenile Justice · filed 2018-02-08(a)(1)
In short, there is simply no evidence that defendant’s termination was based on his race. Consequently, defendant’s motion for summary judgment is granted.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment, and a claim may proceed when a genuine dispute of material fact remains.
Quiroz v. ConocoPhillips Co. · filed 2018-03-05(a)(1)
The Court denies summary judgment on Quiroz' claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e-2, and the New Mexico Human Rights Act, N.M. Stat. Ann. § 28-1-7(A), for racial discrimination.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a) requires evidence that race caused an adverse employment action.
Ghiles v. City of Chicago Heights · filed 2018-03-19(a)
Without more tying this mistreatment to his race, no reasonable jury could determine that Ghiles’s race caused his termination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race-discrimination plaintiff to show an adverse employment action because of race.
Hudson v. Am. Fed'n of Gov't Emps. · filed 2018-04-10(a)(1)
As a member of a protected class, Hudson must show that (1) he suffered an adverse employment action (2) because of his race to prevail on his discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2 leaves a race discrimination claim for the jury when the plaintiff presents enough evidence to cast doubt on the employer’s stated nondiscriminatory reason for its decision.
Thomas v. Home Depot USA, Inc. · filed 2018-04-25
Once a plaintiff produces evidence sufficient to cast doubt on the employer’s proffered non-discriminatory reason, the question of whether race discrimination was the real reason for the adverse employment decision becomes one for the jury to decide.Read the full opinion on CourtListener →
A proposed comparator does not support a race discrimination claim when the record does not establish that person’s race and shows that she worked in a different department under a different supervisor.
Palmer v. University of Illinois · filed 2018-06-20(a)(1)
But the record contains no evidence regarding Young’s race, and Young worked in a different department under a different supervisor.Read the full opinion on CourtListener →
A race discrimination complaint under § 2000e-2(a)(1) can proceed when it adequately alleges that an employer took an adverse employment action because of race.
Gillon v. University of Illinois Health & Science Systems · filed 2018-07-30(a)(1)
Accordingly, Gillon’s Second Amended Complaint adequately alleges that the Board discriminated against her on account of her race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination plaintiff to show an adverse employment action because of race.
Muhammad v. Washington Metropolitan Area Transit Authority · filed 2018-08-09(a)(1)
A race discrimination claim has two elements: (1) “an adverse employment action,” (2) “because of the employee’s race.” Brady, 520 F.3d 493. ... I conclude that no reasonable jury could find that WMATA or its employees intentionally discriminated against Mr. Muhammad on the basis of race.Read the full opinion on CourtListener →
Section 2000e-2(c) bars race discrimination by unions, but the claim fails without evidence that race motivated the union’s refusal to arbitrate.
Motley v. I.A.M.A.W. District Lodge 141 · filed 2018-09-20(c)
Because no reasonable jury could conclude that Motley’s race motivated District Lodge’s decision not to bring his case to arbitration, Ortiz, 834 F.3d at 765, this Court grants summary judgment to District Lodge on Motley’s discrimination claim, see Anderson, 477 U.S. at 252.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a race discrimination claim to proceed when alleged adverse employment actions support a reasonable inference that the employer acted because of race.
Clark v. SMG Corporation · filed 2018-09-30(a)
Therefore, Clark alleges enough to support a reasonable inference that she was subjected to an adverse employment action due to her race and age.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employers from discriminating based on race or sex in hiring, discharge, or compensation.
Mauze v. CBS Corp. · filed 2018-10-17(a)(1)
Mauze asserts claims of discrimination against CBS pursuant to Title VII, which makes it unlawful for an employer to discriminate against an individual in the context of hiring discharge, or compensation, based upon that individual's race or sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence from which a reasonable juror could find that race or color caused the challenged employment action.
Boswell v. Envoy Air / American Eagle · filed 2018-12-31(a)(1)
On this record, no reasonable juror could find that Envoy terminated Boswell because of her race or color.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination claim to connect the challenged employment action to race.
James v. Get Fresh Produce Inc. · filed 2018-11-28(a)(1)
To the extent that James’s Complaint alleges that his vacation requests for March 31 and June 30 were denied on account of his race, although this claim appears to have been included in his Charge of Discrimination and therefore has been properly exhausted, Get Fresh argues that the claim should be dismissed as insufficiently pled. (Dkt. 10) at 2. Get Fresh is correct.Read the full opinion on CourtListener →
Under Section 2000e-2(a)(1), an employee challenging a discharge as race discrimination must show that the employer’s stated nondiscriminatory reason is pretextual once the employer offers one.
Lowe v. Exel, Inc. · filed 2019-01-31(a)(1)
Even assuming Lowe has satisfied the first step in the McDonnell Douglas framework by making out a prima facie case of race discrimination, we conclude that he has failed to demonstrate that Exel’s explanation for his termination is pretextual.Read the full opinion on CourtListener →
A race-discrimination plaintiff relying on circumstantial evidence must show that similarly situated employees outside the protected class received more favorable treatment.
Jackson v. Double Back Transportation · filed 2019-05-06(a)(1)
Regardless, Jackson has failed to establish a prima facie case because he has not demonstrated that he was treated less favorably than similarly situated individuals outside his protected class.Read the full opinion on CourtListener →
A Title VII race discrimination complaint must allege specific facts suggesting intentional discrimination; conclusory claims of harsher discipline do not suffice.
Keithroy B. Nurse v. The City of Alpharetta · filed 2019-05-31(a)
The Plaintiff has alleged no facts whatsoever suggesting intentional discrimination. He has offered neither a comparator nor any other specific facts that would raise his claim above the purely speculative. We simply cannot tell who was treated differently on ... account of race or how. Thus, the district court did not err in dismissing Nurse’s Title VII race discrimination claim for failure to state a claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; an employee relying on comparator evidence must identify similarly situated employees outside the protected class who were treated more favorably.
Williams v. Extra Space Storage, Inc. · filed 2019-07-09(a)(1)
Notwithstanding his allegation in the complaint that “[o]ther similarly situated white employees” were not terminated for allowing the use of rental units without a signed contract, Compl. ¶ 4, ECF No. 1, Williams has not identified any comparable non-African American employee who engaged in similar conduct but was not terminated.Read the full opinion on CourtListener →
Section 2000e-2(a) requires an actionable adverse employment action because of the employee’s race.
Horsey v. United States Department of State · filed 2019-07-18(a)
In sum, Horsey’s amended complaint fails to allege that the State Department took any actionable adverse employment action against Horsey because of his race. Therefore, the complaint fails to raise a plausible Title VII discrimination claim and Horsey’s first count must be dismissed.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment, and a claim survives dismissal when alleged facts plausibly suggest intentional differential treatment based on race.
Mitchell v. Northport, City of · filed 2019-07-24(a)(1)
Title VII similarly prohibits, among other conduct, “discriminat[ion] against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race. . . .” 42 U.S.C. § 2000e-2(a)(1). ... Although Mitchell alleges that this differential treatment was due to Payne’s membership in the NFO, the Court cannot at this time dismiss Mitchell’s race discrimination claim when he has plausibly alleged facts suggesting, as an alternative basis for Chief Marshall’s actions, intentional discrimination and differential treatment based on his race.Read the full opinion on CourtListener →
A race-discrimination claim under Section 2000e-2(a)(1) requires evidence that race caused an adverse employment action; speculation about motive is insufficient.
Allen-Noll, Taysheedra v. Madison Area Technical College · filed 2019-07-29(a)(1)
Apart from conclusory allegations and her own speculation about defendants’ motives, Allen-Noll has not adduced any admissible evidence that her performance was called into question and that she was eventually terminated either because of her race or because her complaints of racial harassment and discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from firing an employee because of race; a race discrimination claim cannot survive summary judgment without evidence that race caused the firing.
Nance v. NBC Universal Entertainment · filed 2019-07-29(a)(1)
Viewing the record as a whole, the Court concludes that no reasonable jury could find that Nance was terminated based on his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence connecting a racially hostile remark to a termination decision; the remark alone is insufficient when its content is unrelated to that decision.
Williams v. Housing Opportunities for Persons with Exceptionalities · filed 2019-07-15(a)(1)
Her comment evinces discriminatory animus and is unbefitting of any workplace. But a reasonable jury could not find that she fired him because of his race based only on that statement because its content bears no relation to the termination decision.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race motivated an adverse employment decision; employees whose conduct and disciplinary histories differ materially may not serve as comparators.
McBride v. Washington Metropolitan Area Transit Authority · filed 2019-08-08(a)(1)
Because McBride has not identified a proper comparator or other circumstantial or direct evidence of discrimination, I will grant summary judgment in WMATA’s favor.Read the full opinion on CourtListener →
Section 2000e-2 allows a race discrimination claim to proceed when the complaint alleges that the employer took an adverse action because of the employee’s race or color.
Arms v. Milwaukee County · filed 2019-08-09
The only question is whether she has alleged disparate treatment. She has. As such, the motion to dismiss her race discrimination claim will be denied.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; when an employer gives nondiscriminatory reasons for its decision, the employee must produce evidence that those reasons are a pretext for discrimination.
Hilliary v. FlightSafety International, Inc. · filed 2019-08-27(a)(1)
Title VII makes it unlawful for an employer to discriminate on the basis of an employee’s race. 42 U.S.C. § 2000e-2(a)(1). ... Plaintiff has failed to show that FSI’s proffered reasons are so implausible, inconsistent, or incoherent that a reasonable factfinder could infer that the reasons were untrue or a pretext for discrimination. Nor has Plaintiff presented evidence tending to show that FSI’s business decision was motivated by discriminatory animus.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence of discrimination; allegations alone do not defeat summary judgment when the employer gives legitimate reasons and the plaintiff offers no evidence of pretext.
Walker v. Blanchard Refining Company LLC · filed 2019-08-28(a)(1)
Walker is unable to satisfy the pretext burden because he has not provided any evidence that would allow a trier of fact to conclude that Blanchard unlawfully discriminated against him.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not treat Jewish heritage as a race for a Title VII race discrimination claim.
Bonadona v. Louisiana College · filed 2019-08-28(a)(1)
At the time it was passed, the Jews were not thought of as a separate race. ... Accordingly, we do not find a valid claim has been made under Title VII for discrimination based on race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to proceed when the complaint plausibly alleges an adverse employment action and facts supporting an inference of discriminatory motivation.
Humphreys v. New York City health and Hospitals Corporation · filed 2019-09-23(a)(1)
Liberally construing the allegations in Plaintiff’s Third Amended Complaint, and considering the minimal burden required to allege facts that suggest an inference of discriminatory motivation, I conclude that Plaintiff has sufficiently alleged a claim of race-based discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim to survive dismissal when the alleged facts plausibly show disparate treatment based on race.
Dieng v. American Institutes for Research in the Behavioral Sciences · filed 2019-09-26(a)(1)
Construing the allegations in the light most favorable to Ms. Dieng, the Court therefore finds that she has alleged enough facts to state a disparate treatment claim based on her race to survive the motion to dismiss.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from discharging or otherwise discriminating against an individual because of race.
Holmes v. Clover, Town of · filed 2019-09-10(a)(1)
Title VII makes it unlawful for an employer “to fail or refuse to hire or to discharge any individual or otherwise discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin; . . . .” 42 U.S.C. § 2000e-2(a)(1). ... Accordingly, the court finds that summary judgment is appropriate for Clover as to Holmes’ Title VII race discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination complaint to allege facts connecting the employer’s conduct to the plaintiff’s race.
Young v. FedEx Employees Credit Assoc. · filed 2019-10-17(a)(1)
Plaintiff’s amended complaint has thus failed to state a race discrimination claim under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from taking an adverse employment action because of an employee’s race.
Gray v. John E. Zaruba, Sheriff of DuPage County · filed 2019-10-25(a)(1)
To succeed on his Title VII claim, Plaintiff must prove three elements: (1) he is a member of a protected class; (2) he has been the subject of some form of adverse employment action; and (3) Defendant took this adverse action on account of Plaintiff’s membership in the protected class.Read the full opinion on CourtListener →
A race discrimination claim fails when the employer gives a nondiscriminatory reason for its decision and the employee offers no evidence of pretext.
Watson v. Esper · filed 2019-12-04(a)(1)
Because Watson offers no evidence to rebut the Army’s reasons, summary judgment is appropriate.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting a plausible inference that an adverse employment action was motivated by race.
Williamson v. Board of Regents of the University of Oklahoma · filed 2019-12-04(a)(1)
Because Plaintiff provides no factual context from which an inference of racial discrimination could plausibly be drawn, the Court finds that Plaintiff’s Title VII race discrimination claim should be dismissed.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination in employment, and a discharge claim requires evidence from which a reasonable factfinder could conclude that race caused the discharge.
Phillips v. Spencer · filed 2019-12-10(a)
Title VII prohibits workplace discrimination on the basis of race, 42 U.S.C. § 2000e–2(a), as well as employer retaliation against employees who oppose workplace discrimination, 42 U.S.C. § 2000e–3(a). For both types of claims, the ultimate question at the summary-judgment stage is essentially the same: whether the evidence, taken as a whole, would permit a reasonable factfinder to conclude that Phillips’s race, or his complaints about discrimination, caused his discharge.Read the full opinion on CourtListener →
Section 2000e-2(a) requires facts supporting a claim that an employee was treated less favorably because of race or color; alleging that another group received a benefit is insufficient without facts connecting the difference to race or color.
Hooper v. Esper · filed 2019-12-13(a)
The complaint is void of any allegations that similarly situated employees of a different race or color were treated more favorably. For this reason, plaintiffs Title VII allegations fail to state a claim for employment discrimination and will be dismissed on initial review.Read the full opinion on CourtListener →
Under § 2000e-2(a), different treatment does not support an inference of race discrimination when the other employees’ misconduct was less serious.
COLEMAN v. JUSTUS AT WOODLAND TERRACE, LLC · filed 2019-12-31(a)
None of the alleged comparators engaged in conduct of comparable seriousness as Coleman’s misconduct in abandoning her job; thus, the different treatment does not raise a reasonable inference of race discrimination.Read the full opinion on CourtListener →
Under the McDonnell Douglas framework, a race discrimination plaintiff must show that she met her employer’s legitimate expectations and that a similarly situated employee outside her protected class was treated more favorably.
MARTIN v. JUSTUS AT WOODLAND TERRACE LLC · filed 2019-12-31(a)
Martin cannot show that she was meeting Woodland Terrace’s legitimate expec- tations or that a similarly situated employee outside the protected class was treated more favorably than she. Therefore, Woodland Terrace is entitled to summary judg- ment on her race discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race disparate treatment complaint without direct evidence to plausibly allege adequate job performance and different treatment of similarly situated employees outside the plaintiff’s protected class.
Marks v. Cary Hotels//Cambria · filed 2020-01-02(a)(1)
Because plaintiff fails to plausibly allege similarly situated employees of a different race were treated differently, and because she fails to allege adequate job performance, plaintiff's complaint is deficient under Rule 12(b)(6).Read the full opinion on CourtListener →
Section 2000e-2(a) permits a race discrimination claim to proceed when the employee plausibly alleges that race influenced an employer’s disciplinary decision.
Shields v. Leeds, City of · filed 2020-02-05(a)
He also has plausibly alleged that Defendant improperly considered his race when deciding his discipline.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires factual allegations that plausibly connect an employee’s discharge to race.
Gass v. Nguyen · filed 2020-02-21(a)(1)
Here, the Complaint lacks many facts, but the factual allegations it contains are insufficient to support a plausible claim for racial discrimination.Read the full opinion on CourtListener →
A Title VII race-discrimination plaintiff relying on indirect evidence must show that the employer’s stated nondiscriminatory reasons were pretextual or that its actions were motivated by discrimination.
Banks v. Board of Education of Anne Arundel County · filed 2020-02-12(a)
... she has not provided sufficient evidence to create a genuine dispute of material fact that ... the Board’s legitimate, nondiscriminatory reasons are pretextual or that the Board’s actions were motivated by discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to survive summary judgment when evidence supports finding that a biased investigator’s input caused the employee’s termination.
Taylor v. Cook County Sheriff's Office · filed 2020-03-04(a)(1)
Taylor has provided sufficient evidence to survive summary judgment on his Title VII race discrimination claim against the Sheriff’s Office.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination claimant to plead facts connecting an adverse employment action to race.
NELSON v. WHOLE FOODS MARKET GROUP INC. · filed 2020-03-09(a)(1)
Nelson has not alleged facts sufficient to show that he was denied a pay raise or terminated because of his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a claim based on an allegedly denied promotion fails when the record shows the promotion was approved.
Hudson v. American Federation of Government Employees · filed 2020-03-17(a)(1)
Title VII makes it unlawful for an employer to “discriminate against any individual . . . because of such individual’s race.” 42 U.S.C. § 2000e-2(a)(1). ... The evidence shows that in February 2017, some eight months before Hudson filed this suit, Cox clearly approved his request. ... There is little doubt that AFGE is entitled to summary judgment on this claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from discriminating in the terms or conditions of employment because of race.
Calise v. U.S. Equal Employment Opportunity Commission · filed 2020-03-19(a)(1)
Plaintiff has not adduced evidence demonstrating she was denied overtime, let alone evidence she was denied overtime on account of her race.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination in employment; a claim fails when the employer gives legitimate, nondiscriminatory reasons for its actions and the employee offers no evidence of pretext.
ROBINSON v. FRANCISCAN ALLIANCE · filed 2020-03-24(a)
And Franciscan has articulated legitimate, nondiscriminatory reasons for each action that it took, and Robinson has no evidence of pretext.Read the full opinion on CourtListener →
A Title VII race discrimination claim requires evidence from which a jury could find that race caused the adverse employment action.
Gamble v. Fiat Chrysler Automobiles · filed 2020-03-25(a)(1)
Gamble has failed to make out a prima facie case of racial discrimination because he has not shown that FCA treated any similarly situated non-black individual differently. Even if he could make out a prima facie case, FCA had a legitimate, non-discriminatory, and non-pretextual reason for firing him. FCA is therefore entitled to summary judgment as to the Title VII racial discrimination claim.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) can survive dismissal when the employee alleges facts supporting discriminatory treatment, including replacement by a white employee or less favorable treatment than a similarly situated white employee.
Hardmon v. Coleman · filed 2020-03-31(a)(1)
When construing all of Plaintiff’s alleged facts as true, as the Court must at the motion to dismiss stage, he has successfully alleged facts that support a prima facie case of race discrimination on two separate grounds. Therefore, Defendant’s motion to dismiss [Record Document 29] is DENIED as to Plaintiff’s claim of race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not support a racial discrimination claim when the employer gives nondiscriminatory reasons for its actions and the employee fails to show those reasons were pretextual.
Boone v. Publix Super Markets, Inc. · filed 2020-04-07(a)(1)
In sum, even if Boone could establish a prima facie case for discrimination, Publix is entitled to summary judgment on Boone’s racial discrimination claims in Counts I, II, and III because Publix has produced nondiscriminatory reasons for its actions, and Boone has not provided sufficient evidence to establish that these reasons were pretextual.Read the full opinion on CourtListener →
A plaintiff’s subjective certainty that race motivated her firing, based on being the only racial minority on her team, cannot defeat summary judgment.
Walker v. Children's Hospital of Wiscons · filed 2020-04-13(a)
Finally, we agree with the district court that Walker points to no evidence that race motivated her firing. Her subjective “certainty” that race had to be a factor because she was the only racial minority on her team is not evidence of discrimination that can avoid a summary judgment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employment discrimination because of race or sex; an employee challenging an employer’s stated reason for termination must offer evidence that the reason was a pretext for discrimination.
Reid v. Aubrey's Restaurant Inc. · filed 2020-04-20(a)(1)
Plaintiff has not offered any evidence that would suggest Defendant’s reason for his termination was a pretext for discrimination on the basis of his race or sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race caused the challenged employment action; an employee’s unsupported belief is insufficient to survive summary judgment.
EDWARDS v. INDIANA UNIVERSITY · filed 2020-04-29(a)(1)
In sum, glaringly absent from this case is any evidence whatsoever that IU’s handling of A.L.’s allegations and Mr. Edwards’ treatment and ultimate termination were based in any way on race. Accordingly, the Court GRANTS IU’s Motion for Summary Judgment on Mr. Edwards’ Title VII race discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits firing an employee because of race, and a plaintiff opposing summary judgment must offer evidence from which a jury could infer that race caused the firing.
Hereford, Renette v. Catholic Charities, Inc., Diocese of Madison · filed 2020-05-05(a)(1)
Title VII prohibits race discrimination in the terms and conditions of employment. 42 U.S.C. § 2000e-2(a). ... To survive summary judgment, Hereford must provide evidence from which a jury could infer that she was fired because of her race.Read the full opinion on CourtListener →
Race need only be a motivating factor in an employment practice, even if other factors also motivated it.
Kilgore, III v. FedEx Freight · filed 2020-05-07(m)
Because a claim under § 1981 requires but-for causation, unlike a claim under Title VII (which requires that race be a motivating factor, 42 U.S.C. § 2000e-2(m)), it is more akin to a claim under the Age Discrimination in Employment Act (“ADEA”).Read the full opinion on CourtListener →
Notes 4051–4200 of 12,593, oldest cases first.
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