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
A plaintiff relying on a comparator to plead race discrimination under Section 2000e-2(a) must allege facts showing that the comparator was similarly situated in all material respects.
Sheets v. Winslow, City of · filed 2020-06-12(a)
This time the SAC identifies a white counterpart’s name (Shipley) and position (Officer), but it again fails to demonstrate how Shipley and Plaintiff were similar in all material respects.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a racial disparate-treatment claim to proceed when the alleged facts reasonably suggest that the employer mistreated and fired the employee because of race.
Offer v. Hershey Entertainment & Resorts Company · filed 2020-06-18(a)(1)
Taken together, Offer’s amended complaint suggests that he—unlike colleagues who were not in his protected class—was mistreated and eventually fired because of his race. Under the circumstances, we can infer from Offer’s allegations that discovery may support his claims. We will deny Hershey’s motion to dismiss the discrimination counts.Read the full opinion on CourtListener →
Section 2000e-2(a) allows a race-discrimination claim to proceed when the alleged facts minimally support an inference of discriminatory intent.
Calvelos v. City of New York · filed 2020-06-22(a)
Under Title VII, the plaintiff must allege “at least minimal support for the proposition that the employer was motivated by discriminatory intent.”Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) must allege facts supporting a plausible inference of discriminatory intent; conclusory allegations are insufficient.
Reppert v. Santiago · filed 2020-07-28(a)(1)
These allegations, however, lack specificity and are conclusory; thus, they allow no inference of discriminatory intent.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race-based termination; circumstantial evidence must allow a reasonable jury to infer that race motivated the employer’s decision.
Nix v. Lowe's Home Center, Inc. · filed 2020-07-30(a)(1)
Based on the evidence before the court, no reasonable jury could infer from the evidence that Lowe’s terminated Mr. Nix based on discriminatory reasoning related to his race, as opposed to the belief that he engaged in fraudulent behavior.Read the full opinion on CourtListener →
An employee alleging race-based discharge must offer evidence that the employer’s stated reason was pretextual and that discrimination was the real reason.
Boumekpor v. Walmart · filed 2020-08-07(a)(1)
Plaintiff’s case ultimately founders because it is supported only by speculation, and Defendant is entitled to summary judgment on Plaintiff’s race discrimination claim.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2 fails when the employee lacks evidence that the employer’s stated reason for termination was a pretext for racial animus.
WHITMORE v. MAFCO WORLDWIDE, LLC · filed 2020-08-13
There is simply inadequate evidence from which a reasonable juror could conclude the proffered reason was tainted by pretext intended to obscure and justify a racial animus.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a race discrimination claim when a plaintiff plausibly alleges an adverse employment action and more favorable treatment of similarly situated employees outside the protected class.
Murray v. City of Warren · filed 2020-08-19(a)
Contrary to Defendants’ argument, Plaintiff has alleged an adverse employment action because he was purportedly terminated and/or constructively discharged. ... Accordingly, Plaintiff has stated a viable race discrimination claim under both Title VII and the ELCRA.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; a discrimination claim requires facts plausibly linking the employer’s decision to the employee’s race.
Olsson v. ABM Taxi Dispatch LaGuardia Airport · filed 2020-08-26(a)(1)
In short, Plaintiff has not alleged facts sufficient to plausibly demonstrate that ABM terminated him based on his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from discriminating against an individual in employment because of race.
Brewer v. BOARD OF TRUSTEES OF THE UNIV. OF ILL. · filed 2005-12-22(a)(1)
Title VII makes it unlawful for an employer to discriminate against an individual in his employment based on that person’s race.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits employment discrimination based on race, color, religion, sex, or national origin; an allegation of termination based on race and color states a Title VII claim.
Nash v. Dungarvin Wisconsin LLC · filed 2020-09-08(a)
The plaintiff states a claim under Title VII, which prohibits an employer from discriminating on the basis of “race, color, religion, sex or national origin.” Abrego v. Wilkie, 907 F.3d 1004, 1012 (7th Cir. 2018) (quoting 42 U.S.C. §2000e-2(a)).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race and color discrimination in employment; a claim must allege facts supporting the employee’s qualifications and discriminatory treatment or motive.
Hicks v. C.P. Squires Elementary School · filed 2020-09-22(a)(1)
Here, Hicks fails to state a claim for race or color discrimination under Title VII or NRS 613.330 because his allegations do not meet the second and fourth elements.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence from which a reasonable factfinder could conclude that race motivated a firing, including evidence of pretext when the employer gives a legitimate reason.
BAILEY v. SOUTH JERSEY PORT CORPORATION · filed 2020-09-23(a)(1)
Absent any other evidence, Bailey has failed to provide enough evidence for a reasonable factfinder to determine that an invidious reason motivated the Port when it fired Bailey for the October 22, 2018 incident. Accordingly, the court will grant the motion of defendant for summary judgment as to Count I of plaintiff’s complaint regarding racial discrimination under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination complaint to allege facts supporting the claim; conclusory allegations of racism and bullying are insufficient.
Green v. Crest Discount Foods Inc · filed 2020-10-06(a)(1)
Plaintiff fails to allege that he is a member of any particular racial minority. Moreover, Plaintiff fails to allege that other employees were treated differently. ... Thus, Plaintiff fails to state a Title VII discrimination claim upon which relief can be granted.Read the full opinion on CourtListener →
A race discrimination claim cannot survive summary judgment without evidence from which a jury could find the employer’s stated reason for termination false.
Lee v. Safe-Dry Carpet and Upholstery · filed 2020-10-14(a)(1)
Mr. Lee has not carried his burden of presenting evidence from which a reasonable jury could find that Safe Dry’s articulated reason for his termination was false.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) requires plausible allegations connecting an adverse employment action to race.
Wright v. CGS Administrators · filed 2020-10-19(a)(1)
Title VII makes it unlawful for an employer to discharge an employee because of her race or color. 42 U.S.C. § 2000e-2(a)(1). ... Rather, Plaintiff alleges that she was terminated for requesting additional training. (Id.) This is insufficient to state a racial discrimination claim under Title VII. Accordingly, to the extent Plaintiff has brought a Title VII claim, it must be dismissed for failure to state a claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires specific evidence of discriminatory motive; vague allegations of racial bias cannot sustain a discrimination claim at summary judgment.
Jones v. Brennan · filed 2020-11-16(a)(1)
But Jones only offers vague allegations of racially motivated conduct; she fails to identify the conduct with specificity, let alone support that it was based on impermissible animus.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employment discrimination based on race or color; allegations of discriminatory termination and unequal employment terms can survive initial review.
McRae v. Niagara Bottling · filed 2020-11-16(a)(1)
Title VII provides that an employer shall not “discriminate against any individual … because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e- 2(a)(1). Here, Plaintiff alleges discriminatory termination, retaliation, and unequal terms and conditions of employment. [Doc. 8 at 3-4; Doc. 8-1 at 1-7]. Taking Plaintiff’s allegations as true and giving him the benefit of every reasonable inference, the Court finds that these claims are not clearly frivolous and survive initial review.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2 requires evidence that race motivated the challenged employment decision.
Andrews v. Exxon Mobil Corporation · filed 2020-11-18(a)
In addition, while it is true that had Plaintiff not been placed on DML status he likely would not have been terminated, there is no evidence that the DML status was used to make it easier to terminate Plaintiff because of his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a claim may proceed when disputed evidence could allow a jury to find that an employer shifted customers from Black sales representatives to white sales representatives.
Sims v. Sunovion Pharmaceuticals, Inc. · filed 2020-11-20(a)(1)
Although a close call, the Court finds that there are genuine disputes of material fact with respect to Plaintiff’s racial discrimination claim predicated on her allegations that Defendant removed target customers from her and another African American sales representative to the benefit of white sales representatives. On this allegation only, the Court concludes that a reasonable jury could find for Plaintiff based on the present record.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race caused an adverse employment action; employees offered as comparators must be materially comparable.
Bandy v. Kocel · filed 2020-11-30(a)(1)
Because Bandy has not shown that she was transferred and terminated because of her race, her age, or her prior EEOC grievance, and has not shown that employees similarly situated to her were systematically treated differently from her, she cannot establish a genuine issue for trial as to the discrimination and retaliation claims.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a plaintiff alleging race discrimination to plead facts suggesting that an adverse employment action was based on race.
Felder v. Atria Builders · filed 2021-01-05(a)
Plaintiff’s allegations of discrimination under Title VII and the ADEA are also insufficient to state claims under these statutes. Plaintiff does not allege facts suggesting that his employer took any adverse action against him based on his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a racial discrimination claim over a termination to proceed when evidence creates a genuine dispute about whether the employer’s stated reason was a pretext for discrimination.
Slater v. Houston Wire & Cable Company · filed 2021-01-11(a)(1)
Under Title VII and Section 1981, it is “an unlawful employment practice 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)(1). ... The Court finds, at this juncture, that the Plaintiff has proffered sufficient evidence to show that there is a genuine issue of material fact regarding the Defendant’s proffered reason for termination, and whether it is true or is a pretext for discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim to proceed at screening when an employee alleges that, because of his race, he was denied a workplace privilege available to coworkers.
Hicks v. C.P. Squires Elementary School · filed 2021-01-20(a)(1)
For screening purposes, the Court finds that this allegation sufficiently meets the third element. Hicks meets the fourth element, as he alleges Landeros and Bosacker proscribed him from the using the weight room because of his race, while allowing other non-Black custodians to continue using it. Accordingly, the Court will allow Hicks’ claims for racial discrimination under Title VII and NRS 613.330 to proceed.Read the full opinion on CourtListener →
A racial discrimination claim cannot survive summary judgment on conclusory assertions of bias without evidence that the employer’s stated reason for discharge was a pretext.
Jones v. Gulf Coast Restaurant Group Inc · filed 2021-01-22(a)(1)
Jones has proffered no evidence that Half Shell’s decision to terminate him was motivated by discriminatory animus.Read the full opinion on CourtListener →
Section 2000e-2(a) protects employees from race discrimination based on their association with or advocacy for a person of a protected race.
Al Karakushe v. Auburn Fields Hotel, Inc. · filed 2021-02-03(a)
Title VII forbids employers from discriminating 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). ... For the above reasons, the Court finds that there is a genuine issue of material fact as to whether Namou unlawfully discriminated against Karakushe and DENIES Defendants’ motion regarding the race discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment, but a claim cannot survive summary judgment without evidence from which a reasonable juror could find that the employer acted because of race.
Young v. Brew City · filed 2021-02-16(a)(1)
For these reasons, no rational trier of fact could conclude that Brew City discriminated against Young on account of his race. Brew City is entitled to summary judgment on Young’s discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to proceed when the plaintiff plausibly alleges that she was qualified for her position and was replaced by someone outside her protected class.
Taylor v. Rolle Law · filed 2021-02-25(a)(1)
Contrary to Rolle’s contention, replacement by someone outside the protected class satisfies the fourth element.Read the full opinion on CourtListener →
A race discrimination claim can proceed to trial when the circumstantial evidence, considered as a whole, creates a genuine dispute about whether race motivated an employment decision.
Lewis v. The School Board of Palm Beach County, Florida · filed 2021-03-09(a)(1)
For the reasons we have explained above, we conclude that sufficient circumstantial evidence in the record, considered as a whole and viewed in the light most favorable to Lewis, creates a genuine dispute of fact as to whether the non-renewal decision was motivated by Lewis’s race. See Smith, 644 F.3d at 1328.Read the full opinion on CourtListener →
A plaintiff relying on a comparator to establish race discrimination under § 2000e-2(a) must show that the employment actions occurred under nearly identical circumstances.
Ryan v. United States Department of Commerce · filed 2021-03-18(a)
To establish that element, a plaintiff must “proffer[] a fellow employee as a comparator [and] demonstrate that the employment actions at issue were taken ‘under nearly identical circumstances.’” ... Ryan does acknowledge this argument, but he never offers a comparator.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits adverse employment action because of race, and a complaint must allege facts supporting a plausible inference of that connection.
Royall v. C&C Meat Sales, Inc. · filed 2021-03-19(a)(1)
Accepting all of these factual allegations as true, Mr. Royall fails to state a plausible claim that his termination, or any other adverse employment action, was the result of unlawful racial discrimination against him.Read the full opinion on CourtListener →
A race discrimination claim concerning compensation requires evidence that the compensation was connected to the employee’s race.
Shelton v. Pine Bluff/Jefferson County Library · filed 2021-03-24(a)(1)
The most basic problem for Ms. Shelton is that there is no evidence whatsoever that the compensation package had anything to do with Ms. Shelton’s race.Read the full opinion on CourtListener →
Replacement of African American workers with Caucasian workers can support an inference of race discrimination under Section 2000e-2(a)(1) at the pleading stage.
LAZARD v. ALL RESTORE, LLC · filed 2021-03-29(a)(1)
But, as noted above, the replacement of Plaintiffs on the Jobsite by Caucasians ... raises an inference of discrimination at this stage.Read the full opinion on CourtListener →
In a race-discrimination claim under § 2000e-2(a)(1), disputing alleged misconduct does not show pretext without evidence that the employer did not honestly believe it occurred.
Bacy v. Chickasaw Nation Industries · filed 2021-03-30(a)(1)
Bacy’s pretext argument fails because she has not presented any evidence showing CNI did not honestly believe she was insubordinate.Read the full opinion on CourtListener →
Section 2000e-2(a) requires evidence from which a reasonable jury could find that an employer took an adverse employment action because of race.
Hickey v. City of Chicago Board of Education · filed 2021-04-13(a)
In sum, Hickey cannot point to any evidence from which a reasonable jury could conclude that the Board laid Hickey off and did not rehire her because she is white and does not speak Spanish.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a plaintiff relying on circumstantial evidence must present a suitable comparator or other evidence permitting an inference of intentional discrimination.
Nelson v. Health Services, Inc. · filed 2021-04-19(a)(1)
Because discrimination is the act of “treating like cases differently,” Lewis, 918 F.3d at 1222, summary judgment is due to be granted on the Plaintiff’s Title VII and § 1981 Disparate Treatment claims.Read the full opinion on CourtListener →
Section 2000e-2(a) requires evidence connecting alleged racial bias to the challenged layoff; bias without that connection cannot sustain a race discrimination claim.
Alvares v. Board of Education of the City of Chicago · filed 2021-05-10(a)
Viewing all of the evidence in the light most favorable to Alvares, a juror might infer that McGill didn’t like Alvares and treated her harshly. But that is not enough to suggest racial motivation for the termination. Travis supplies some admissible evidence of racial bias on McGill’s part, but the connection to Alvares’s layoff is nonexistent.Read the full opinion on CourtListener →
A race discrimination claim can survive summary judgment when evidence about comparable employees and disputed reasons for termination could permit a finding of discrimination.
Dawson v. Assured Partners · filed 2021-05-10(a)(1)
Although this is far from the strongest case that the Court can imagine, the Court is not satisfied that no rational factfinder could conclude that Plaintiff's termination was discriminatory, and will deny summary judgment on Plaintiff's race discrimination claim, but only to the extent that Plaintiff has alleged less favorable treatment using Ms. Howard and Ms. Jeffries as comparators.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts showing that race or ethnicity caused an adverse employment action.
Bentley v. Home Care Assistance · filed 2021-05-11(a)(1)
To state a claim for race-based employment discrimination, the plaintiff must state facts showing that the plaintiff’s race or ethnicity “caused the discharge or other adverse employment action.” ... The court plaintiff has not stated a claim for discrimination based on race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim to proceed when evidence of pretext and a prima facie case create a genuine factual dispute, even if a same actor inference may apply.
Grelle v. City of Windcrest · filed 2021-05-12(a)(1)
Thus, whether or not the presumption applies, Defendant is not entitled to judgment as a matter of law on Plaintiff’s Title VII claim for discrimination on the basis of race.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race discrimination by employers; allegations that an employee was fired while a similarly situated employee of another race received more favorable treatment can state a claim.
Crowder v. Progressive Parking Solutions · filed 2021-05-18(a)
The plaintiff has asserted that he is African American; race is a protected class under Title VII, 42 U.S.C. §2000e-2(a)). He asserts that a Caucasian person who did what he did—used his cell phone—was treated more favorably than he was. ... The court concludes that the plaintiff has stated a claim for employment discrimination under Title VII.Read the full opinion on CourtListener →
Section 2000e-2 requires evidence that an employee was fired or harassed because of race to sustain a race-discrimination claim.
Freeman v. Molding Products · filed 2021-05-19
Freeman’s claim fails because he adduced no evidence that would permit a reasonable factfinder to conclude that Molding fired or harassed him because of his race.Read the full opinion on CourtListener →
A race discrimination plaintiff can establish the fourth element of a prima facie claim by showing that a similarly situated employee outside the plaintiff’s protected group received more favorable treatment.
Ernst v. Methodist Hospital · filed 2021-06-08(a)(1)
To satisfy the fourth element, a plaintiff must point to a comparator who was “similarly situated” and received more favorable treatment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence from which a reasonable factfinder could conclude that race caused an adverse employment action.
Moten v. Insinkerator · filed 2021-06-09(a)(1)
To survive summary judgment on his discrimination claim, Moten must submit evidence that would permit a reasonable factfinder to conclude that his race caused an adverse employment action. ... Based on this evidence, no reasonable fact finder could conclude that ISE treated a similarly situated employee outside of Moten’s protected class more favorably.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race motivated an employee’s termination; an employer’s decision to terminate both employees involved in a physical altercation does not establish race discrimination.
Hassan v. Sanford Medical Center · filed 2021-06-14(a)(1)
The Court finds that based on the evidence in the record, no reasonable juror could conclude that discrimination was a motivating factor in Hassan’s termination.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) survives dismissal when the pleaded facts make discrimination plausible; the plaintiff need not establish a prima facie case at the pleading stage.
Hundley v. WAWA, INC. · filed 2021-06-22(a)(1)
Defendant’s Motion to Dismiss under R. 12(b)(6) will be denied because Plaintiff makes a plausible claim of discrimination pursuant to Iqbal-Twombly and is not required to establish all elements of the prima facie case at the pleading stage.Read the full opinion on CourtListener →
Section 2000e-2(a) requires circumstances supporting an inference that an employee was fired because of race.
DEAN v. PHILADELPHIA GAS WORKS · filed 2021-06-28(a)
The evidence shows no connection between Dean’s termination and his race, and Dean cannot establish the fourth element of his prima facie case.Read the full opinion on CourtListener →
Section 2000e-2(a) requires evidence that race caused an adverse employment action to sustain a discrimination claim at summary judgment.
Marigny v. Centene Management Company LLC · filed 2021-06-30(a)
To survive summary judgment on her discrimination claim, Marigny must show evidence sufficient for a reasonable jury to find that she was subject to a materially adverse employment action because of her age or race. ... The decision to terminate Marigny was not based on her age or race.Read the full opinion on CourtListener →
Section 2000e-2(a) allows a race discrimination claim against an employer when an employee adequately alleges that she was terminated because of her race.
James v. TCA Health, Inc. · filed 2021-07-08(a)
In short, the Court finds, in viewing the allegations of the Complaint in the light most favorable to Dr. James, and drawing all reasonable inferences in her favor, that Dr. James adequately alleges a Title VII and Section 1981 race discrimination claim against TCA based on her termination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination plaintiff to plead facts plausibly showing an adverse employment action because of race.
Johnson v. Jackson Public School District · filed 2021-07-14(a)(1)
Because Johnson fails to allege sufficient facts that plausibly suggest JPSD fired her because of her race, Johnson does not state a claim for Title VII race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from firing or otherwise discriminating against an employee because of race or sex.
McNeal v. International Paper · filed 2021-07-21(a)(1)
Under Title VII and Section 1981,3 it is unlawful for an employer to “discharge any individual or otherwise to discriminate against any individual” because of the individual’s race or sex. 42 U.S.C. § 2000e-2(a)(1). ... Thus, McNeal’s circumstantial evidence is insufficient to raise a reasonable inference that IP discriminated against her based on her sex or race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting a plausible inference that race motivated an adverse employment action; conclusory allegations of racial bias are insufficient.
Reppert v. Santiago · filed 2021-07-26(a)(1)
Moreover, without facts tying their conduct to Plaintiff’s race, even indirectly, neither Santiago’s hostility toward him and sharp questioning during meetings, Crowell’s reassignment of tasks, nor their exclusion of him from “issues or opportunities,” allow a plausible inference that racial discrimination motivated the denial of promotions to Plaintiff.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from denying a promotion or reducing pay because of an employee’s race.
Harris v. Reneau Inc · filed 2021-07-30(a)(1)
Because Ms. Reneau’s statement leaves no doubt about her intent to discriminate against Ms. Harris on the basis of her race, Ms. Harris has sufficiently stated a colorable claim for disparate treatment in violation of Title VII and 1981.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts plausibly showing that an adverse employment action occurred because of race or color.
McRae v. Niagara Bottling · filed 2021-08-10(a)(1)
Accepting all of these factual allegations as true, Plaintiff fails to state a plausible claim that his termination, or any other adverse employment action, was the result of unlawful racial discrimination against him.Read the full opinion on CourtListener →
Section 2000e-2 allows a race discrimination claim to proceed when evidence that an employee of another race received lesser discipline for similar conduct raises a genuine dispute about the employer’s stated reason for discharge.
Jones v. Federal Express Corporation · filed 2021-08-11(a)(1)
In summary, Jones has presented sufficient evidence to support a prima facie showing of race discrimination, based only on the April 2017 Skeen incidents.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits covered employers from discriminating in the terms, conditions, or privileges of employment because of race.
Tate v. United Steel Workers Union · filed 2021-08-17(a)(1)
Title VII of the Civil Rights Act of 1964 prohibits covered employers from discriminating against any individual with respect to “terms, conditions, or privileges of employment, because of such individual’s race.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race-discrimination plaintiff to show protected status, that the plaintiff met the employer’s legitimate expectations, an adverse employment action, and facts supporting an inference of discrimination.
Danquah v. Target Corporation · filed 2021-08-19(a)(1)
Under both Title VII and the MHRA, to establish a prima facie case of racial discrimination in employment, a plaintiff must show that: (1) the plaintiff is a member of a protected class, (2) the plaintiff met the employer’s legitimate expectations, (3) the plaintiff suffered an adverse employment action, and (4) there are facts supporting an inference of discrimination.Read the full opinion on CourtListener →
A plaintiff using comparator evidence to establish a prima facie Title VII race discrimination claim must show that similarly situated employees outside the protected class received different treatment.
Reynolds v. FCA US LLC · filed 2021-08-24(a)(1)
In sum, none of the evidence Plaintiff cites to support his similarly-situated argument is sufficient to satisfy the fourth prong of a prima facie case for racial discrimination under the McDonnell Douglas / Burdine burden-shifting framework established.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race discrimination claim to proceed when the evidence could allow a jury to find that race motivated an employee’s termination.
Skinner v. Michigan Rod Products, Incorporated · filed 2021-08-25(a)(1)
For all of these reasons, there is a material question of fact regarding whether Defendant intentionally discriminated against Plaintiff on the basis of race when terminating Plaintiff, and Defendant’s motion for summary judgment on this claim is denied.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a) cannot survive summary judgment without admissible evidence connecting the employment decision to race.
QUALLS-HOLSTON v. INDIANA UNIVERSITY · filed 2021-09-03(a)
The Court determines that the admissible, designated evidence does not support Qualls- Holston's race discrimination claim and, thus, summary judgment is appropriate on this claim.Read the full opinion on CourtListener →
A race discrimination complaint under § 2000e-2(a)(1) must plausibly allege that the employee met the employer’s legitimate expectations and that the adverse action resulted from intentional racial discrimination.
Jones v. Live on Nebraska · filed 2021-09-16(a)(1)
However, she has not alleged facts suggesting that she met her employer’s legitimate expectations or that her termination resulted from intentional racial discrimination; therefore, Plaintiff has failed to state a racial discrimination claim upon which relief can be granted.Read the full opinion on CourtListener →
Section 2000e-2(a)(2) prohibits employment decisions based on race; a claim fails when the evidence cannot support an inference that race affected the employer’s decision.
Freeman v. Metropolitan Water Reclamation District of Chicago · filed 2021-09-21(a)(2)
The Court therefore concludes that a reasonable factfinder could not conclude MWRDC denied Freeman an accommodation, or took any action, on account of his race. Summary judgment is therefore granted as to Count V.Read the full opinion on CourtListener →
A discriminatory discharge claim under § 2000e-2(a)(1) requires circumstances supporting an inference that the discharge was based on race.
Arnall v. Pittsburg, Kansas, City of · filed 2021-09-21(a)(1)
Therefore, viewing the evidence in the light most favorable to Mr. Arnall, he fails to create any inference that his discharge was based on unlawful racial discrimination. No reasonable jury, based on the evidence presented, could find for him on that issue. Because there is no genuine dispute of material fact on this issue, the City is entitled to summary judgment on Mr. Arnall’s claim of race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting a reasonable inference that an adverse employment action occurred because of the employee’s race.
Cunningham v. N.C. DHHS · filed 2021-09-22(a)(1)
Here, plaintiff has failed to allege sufficient factual matter to support a reasonable inference that any adverse employment action was because of her race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race-based termination; a claim may survive summary judgment when evidence supports an inference of discrimination and raises a factual dispute over the employer's stated reason.
Jefferson v. Intelligrated Inc · filed 2021-09-16(a)(1)
Here, Plaintiff has established a prima facie case of race and age discrimination and rebutted Defendant's non- discriminatory justification for his termination. Plaintiff's race and age discrimination claims survive summary judgment and will proceed.Read the full opinion on CourtListener →
Law changed since Muldrow v. City of St. Louis (2024) requires some harm to an employment term or condition from a discriminatory transfer, without the older materially-adverse threshold.
Section 2000e-2(a)(1) requires a race discrimination claim to rest on a materially adverse employment action taken because of race.
Beaulieu v. HealthSpring · filed 2021-09-30(a)(1)
Beaulieu points to a variety of different workplace incidents, but for reasons explained below, there is no genuine dispute that each of these incidents either does not rise to the level of an “adverse employment action” or was not taken on account of Beaulieu’s race, or both.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence connecting a termination to race; an employee’s belief that criticism was racially coded does not establish discrimination when the evidence points to misconduct as the reason for termination.
Johnson v. L'Oreal USA · filed 2021-09-30(a)(1)
Thus, while Johnson may have felt that others used racially-coded language toward her and did not treat her fairly, she has not provided any evidence that would give rise to an inference that L’Oréal terminated her because of her race rather than because of her misconduct.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination complaint to plausibly allege an adverse employment action caused by racial discrimination.
Conner v. City of Naples Airport Authority · filed 2021-10-05(a)(1)
Conner does not plausibly allege her termination—or any other adverse employment event—resulted from racial discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires plausible allegations that challenged employment conduct was motivated by the employee’s race or color.
Smith v. Wilkie · filed 2021-10-07(a)(1)
In sum, as Defendant contends, in neither his Amended Complaint nor his proposed Second Amended Complaint has Plaintiff plausibly alleged that the conduct of which he complains was due to his race or color.Read the full opinion on CourtListener →
A race-discrimination claim under § 2000e-2(a)(1) cannot survive summary judgment when the evidence would not allow a reasonable jury to find that race influenced the employee’s termination.
Lockhart v. Srv · filed 2021-10-25(a)(1)
The record simply would not allow a reasonable jury to conclude that Lockhart’s race had anything to do with his termination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits termination because of race or sex; a discrimination claim fails when the evidence cannot support a finding that either caused the termination.
Lawrence v. Energy Solutions · filed 2021-10-27(a)(1)
Because Lawrence has not identified a question of fact as to whether her race or sex caused her termination, the Court finds that she cannot prevail on her race and sex discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination claim to plausibly link an adverse employment action to race.
Wilborn v. Wolf · filed 2021-10-28(a)(1)
Wilborn fails to sufficiently allege that he was discriminated against because of his race. Under Title VII, employers are not permitted 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). ... Here, Wilborn claims he was discriminated against because he is African American, (FAC ¶¶ 29–30), but as Defendant argues, Wilborn fails to ... establish a link between his race and any adverse action taken against him.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; under the McDonnell Douglas framework, an employee must produce evidence that the employer’s stated reasons for discharge were pretext for discrimination.
Moore v. Forrest City School District · filed 2021-11-12(a)(1)
In any event, whether Mr. Moore established a prima facie case does not change the outcome of the Court’s decision here because on this record a rational juror could not conclude that Defendants’ nondiscriminatory reasons for terminating Mr. Moore were pretext for racial discrimination.Read the full opinion on CourtListener →
A circumstantial race discrimination claim under Title VII fails on appeal when the employee does not challenge the finding that the employer’s stated reason was not pretextual.
Dixon v. National Security of Alabama, Inc. · filed 2021-11-16(a)(1)
Therefore, given the absence of an argument demonstrating that DTA’s reason for the elimination of Dixon’s job is a pretext for discrimination, we affirm the district court’s grant of summary judgment dismissing Dixon’s race-based disparate-treatment claim.Read the full opinion on CourtListener →
Section 2000e-2(a) treats race and color discrimination as separate claims; color discrimination can concern differences in skin pigmentation apart from race.
REEVES v. COLUMBUS CONSOLIDATED GOVERNMENT · filed 2021-11-22(a)
Title VII recognizes separate claims for race and color discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race-discrimination claim to proceed when evidence could let a reasonable jury find the employer’s stated nondiscriminatory reason was a pretext for discrimination.
Duncan v. Carson · filed 2021-11-27(a)(1)
In sum, Duncan has offered enough evidence that a “reasonable jury” could find the Secretary’s proffered nondiscriminatory reason is a pretext for race discrimination.Read the full opinion on CourtListener →
Section 2000e-2 requires facts supporting a plausible inference of race discrimination; an unsupported claim that other candidates were less qualified is insufficient.
James v. Borough of Manhattan Community College City of University of New York · filed 2021-11-29
Plaintiff’s conclusions that those outside of her protected classes who were offered the contract were not as qualified as she was, without further information supporting that conclusion, is not sufficient to sustain a minimal inference of discriminatory motivation for the adverse employment action.Read the full opinion on CourtListener →
A Title VII race discrimination complaint need not plead a McDonnell Douglas prima facie case if its factual allegations give the employer fair notice of the claim.
Debro v. Contra Costa Community College District · filed 2021-11-30(a)(1)
Debro alleges sufficient facts to state discrimination claims under these statutes. ... Because these facts put the District on notice of the claims against them, the Court denies the District’s motion with respect to claims one and two.Read the full opinion on CourtListener →
Section 2000e-2 prohibits race discrimination in employment, and a claim may proceed when the alleged facts plausibly support an inference that race caused an employer not to renew a contract.
Ashanti v. City of Richmond School Board d/b/a Richmond Public Schools · filed 2021-12-03
Because Ashanti sufficiently claims that RPS violated Title VII by not renewing her contract based on race discrimination, the Court will deny RPS’s motion to dismiss.Read the full opinion on CourtListener →
A race discrimination claim survives a motion to dismiss when the alleged facts plausibly support an inference that race motivated an adverse employment action.
BROOKS v. PREVENTION POINT PHILADELPHIA, INC. · filed 2021-12-28(a)(1)
Doing so, I find that Plaintiff has plausibly pled sufficient facts to give rise to an inference of discrimination, thereby setting forth a prima facie case of racial discrimination. Accordingly, I will deny Defendant’s motion in this regard.Read the full opinion on CourtListener →
A Title VII race discrimination plaintiff relying on circumstantial evidence must show that the employer’s stated nondiscriminatory reason was pretextual.
Robinson v. Walmart Stores East, LP · filed 2021-12-13(a)
Yet Robinson did not rebut any of the bases for Walmart’s coachings, nor for her final Teal Card policy violation.Read the full opinion on CourtListener →
A race discrimination claim must sufficiently allege that someone outside the plaintiff’s protected class received more favorable treatment.
Virella v. M.B.G. Enterprises Inc. · filed 2022-01-04(a)(1)
Therefore, in light of these conflicting allegations, this Court cannot conclude that Plaintiff has sufficiently alleged that someone outside of her protected class received more favorable treatment. Accordingly, Plaintiff’s Title VII claims are DISMISSED WITHOUT PREJUDICE.Read the full opinion on CourtListener →
A Title VII race discrimination claim cannot survive summary judgment when no reasonable jury could find a prima facie case of discrimination.
Warren v. Hollingsworth Management Services, LLC · filed 2022-01-06(a)
Hollingsworth is entitled to summary judgment on this claim because, considering the undisputed facts in this case, no jury could reasonably find a prima facie case of discrimination.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) fails at the prima facie stage when the employee offers only assumptions without evidence linking the employer’s conduct to race.
COLEMAN v. COMMUNITY BEHAVIORAL HEALTH · filed 2022-01-06(a)(1)
But Plaintiff relies entirely on her own assumptions that her treatment was based on race and provides no evidence of racial animus or favorable treatment of similarly situated comparators based on race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a claim cannot survive summary judgment without evidence that race caused the adverse action.
Vann-Foreman v. Illinois Central Railroad Company · filed 2022-01-20(a)(1)
Nor has she presented any evidence that either Torres-Regnier or Tharpe failed her because she is African American. Indeed, she has identified no racist remarks or any other facts from which a reasonable fact finder could conclude that either Torres-Regnier, Tharpe, or Condon acted based on race. The only racist remark plaintiff has identified was allegedly made by Gerten, who had no input into the decision to test plaintiff or deny her certification. Consequently, the court grants defendant’s motion for summary judgement on Count I.Read the full opinion on CourtListener →
Section 2000e-2(c) prohibits a labor organization from discriminating against an individual because of race, including by excluding or expelling the individual from membership.
Turner v. Thyssenkrupp Elevator · filed 2022-01-28(c)
It is also forbidden for a labor organization to “exclude or expel from its membership, or otherwise to discriminate against,” an individual based upon that individual’s race. 42 U.S.C. § 2000e-2(c). ... For these reasons, the Court denies the Union’s motion to dismiss Plaintiff’s race- based discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires plausible facts connecting a firing to race; pressure from biased coworkers alone did not suffice where the complaint alleged no supervisory or disciplinary authority or role in the formal decision.
Krehbiel v. BrightKey, Inc. · filed 2022-03-04(a)(1)
Plaintiff alleges merely that biased employees pressured Defendant into firing him. He does not allege that those employees had any supervisory or disciplinary authority or that any of them made the formal decision to terminate him.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence that race caused the adverse employment action to sustain a race discrimination claim.
Blackwell-Fripp v. Whitley · filed 2022-03-08(a)(1)
Nor does she identify any evidence in her response suggesting that race played a role in Defendant’s failure to extend her term, making it impossible for a reasonable factfinder to conclude that her race was the reason her term was not extended.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting an inference that an employer acted because of the employee’s own race.
Ledda v. St. John Neumann Regional Academy · filed 2022-03-09(a)(1)
Assuming the truth of these allegations, they provide no indication whatsoever that defendants terminated Ledda “because of such individual’s [here, Ledda’s] race.” See 42 U.S.C. § 2000e-2(a)(1).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts plausibly suggesting that race played a role in the challenged employment action.
PHILLIPS v. MACON BIBB COUNTY GOVERNMENT · filed 2022-03-11(a)(1)
Plaintiff fails to allege facts that might plausibly suggest a reasonable inference that Defendant's purported racial biases played any role in her termination. For that reason alone, the Court must dismiss Plaintiff's race discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting an inference that an adverse employment action was motivated by race; conclusory allegations are insufficient.
Best v. District of Columbia · filed 2022-03-17(a)(1)
Such bare allegations are insufficient to establish the necessary inference that the adverse action was racially motivated.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; a plaintiff relying on circumstantial evidence must show that the employer’s stated reason was pretextual.
Hairston v. Costco Wholesale Corporation · filed 2022-03-29(a)(1)
Title VII makes it unlawful “for an employer . . . to discharge any individual . . . because of such individual’s race, color, religion, sex, or national origin.” See 42 U.S.C. § 2000e-2(a)(1). ... Plaintiff has not met his burden.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits an employer from discharging or otherwise discriminating against an employee because of race or sex.
Hrdlicka v. General Motors LLC · filed 2022-03-31(a)(1)
Title VII provides that it is 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 or sex.Read the full opinion on CourtListener →
A race discrimination claim requires evidence that race motivated the challenged employment actions.
Beaulieu v. NewQuest Management of Illinoi · filed 2022-04-01
Beaulieu furnished nothing suggesting that the unpleasantness she described (name-calling, scolding, close encounters, discipline), the privileges she did not receive (remote-work, extra time off), or the denial of promotion and more pay occurred because of her race.Read the full opinion on CourtListener →
A discrimination complaint must allege facts showing that an adverse employment action was taken because of the plaintiff’s protected class; an unsupported assertion of racial motive is insufficient.
White v. Housing Authority of Queen Anne's County · filed 2022-04-01(a)(1)
The complaint does not, however, provide sufficient information to support a claim that these actions were taken because of his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race-discrimination claim to proceed when the alleged facts plausibly show adverse employment actions and an inference of intentional discrimination.
Carter v. Tomlinson Restaurant Group, LLC · filed 2022-04-01(a)(1)
I conclude that, for purposes of initial review, Plaintiff has plausibly alleged a race-discrimination claim because he alleges that he is a member of a protected class; that he met his employer’s legitimate expectations (and indeed excelled according to many of his customers); that he suffered adverse employment actions such as receiving lower pay than his white coworkers and eventual termination; and he was subjected to racially motivated treatment, raising an inference of intentional discrimination.Read the full opinion on CourtListener →
A requirement that all fire personnel be able to perform all firefighting duties is not, by itself, race discrimination under Title VII.
Larry v. The City of Mobile, Alabama · filed 2022-04-15(a)(1)
The fact that new leadership implemented a plan that required all personnel to be able to perform all firefighting duties (e.g. riding on a fire truck) is not in and of itself discriminatory.Read the full opinion on CourtListener →
For an indirect evidence race discrimination claim, the comparator element concerns how the employer treated similarly situated people outside the plaintiff’s protected class.
Thomas v. Clarksville Montgomery County School System · filed 2022-04-15(a)(1)
But this approach is a misunderstanding of the fourth element of an indirect-evidence prima facie case of race discrimination, which focuses not on the defendant’s process, but rather on the defendant’s treatment of the plaintiff (compared to its treatment of persons outside of the plaintiff’s protected class).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits firing an employee because of race or national origin; a discrimination claim fails when the evidence does not link the termination to either protected trait.
Barry v. Macy's, Inc. · filed 2022-04-13(a)(1)
Moreover, there is not a scintilla of evidence to support the argument that Plaintiff was ultimately fired due to his race or national origin.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discrimination because of an employee’s race; reducing hours because an employee called someone racist does not, by itself, violate that prohibition.
McConnell v. Braum's Ice Cream · filed 2022-04-29(a)(1)
While Title VII makes it unlawful for an employer to discriminate against an individual “because of such individual’s race,” it is not unlawful to reduce an individual’s hours because an individual made statements that her employer is racist.Read the full opinion on CourtListener →
Section 2000e-2(a) bars race-based termination, and a claim may reach a jury when the evidence as a whole permits an inference that race caused the discharge.
Whitmore v. Wheaton Village Nursing and Rehabilitation Center, LLC · filed 2022-05-05(a)
Viewing the evidence together in a single pile—the discriminatory comments, the differential treatment, and the elusive justifications for discharge—a reasonable jury could conclude that Wheaton Village terminated Whitmore because of her race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts supporting a reasonable inference that race or color motivated an adverse employment action to state a discrimination claim.
Rancher v. Hubbell Power Systems · filed 2022-05-17(a)(1)
The court WILL GRANT the motion to dismiss the part of Count Two alleging race and color discrimination claims under Title VII and § 1981 because the amended complaint does not set out any specific factual allegations supporting a reasonable inference that Hubbell’s adverse employment actions were based on race or color discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a claim fails without evidence of a sufficiently hostile workplace or that race caused the employee’s discharge.
McCormick v. Hardy Corporation · filed 2022-05-19(a)(1)
To close, Hardy’s motion, doc. 15, is due to be granted because McCormick fails to establish that Hardy created a hostile work environment or discharged him because of his race in violation of Title VII.Read the full opinion on CourtListener →
A Title VII race discrimination claim can survive summary judgment when genuine factual disputes concern the employee’s performance, a similarly situated comparator, and whether the employer’s stated reason was pretextual.
JETT v. ISS FACILITY SERVICES, INC · filed 2022-05-03(a)(1)
This evidence creates genuine issues of material fact on the issues of whether Mr. Jett was meeting ISS's legitimate expectations, whether Mr. Jett has identified a similarly situated comparator, and whether Mr. Jett has presented evidence that ISS's stated reason for terminating him was pretextual, and includes the following: ... Mr. Jett had cataracts due to a medical condition and could not perform the LOTO Procedure at the time of the November 13, 2019 Incident.Read the full opinion on CourtListener →
Section 2000e-2(a) allows a race discrimination claim to proceed when the complaint plausibly alleges that race motivated an adverse hiring decision.
Florence v. Seggos · filed 2022-06-07(a)
To state a Title VII claim, a plaintiff need only plausibly allege that race was a “motivating factor” with respect to the adverse employment decision. ... The district court erred in holding that the SAC failed to state a Title VII claim.Read the full opinion on CourtListener →
Section 2000e-2 requires evidence that an employment decision was made because of race to support a race discrimination claim.
ANDERSON v. LOWE'S HOME CENTERS, LLC · filed 2022-06-14
Here, Anderson’s race discrimination claim fails as a matter of law because he has not identified any evidence from which a jury could reasonably infer that Lowe’s treated Anderson differently than non-Black employees and either placed him on a PIP or denied his May 2019 transfer request because of his race.Read the full opinion on CourtListener →
An employer’s decision to bypass a discretionary progressive discipline policy does not, by itself, support an inference of race discrimination.
Rice-Smith v. Misericordia Convalescent Home · filed 2022-06-21(a)(1)
Misericordia’s decision to terminate Rice-Smith rather than utilize its progressive disciplinary system does not give rise to an inference of discrimination.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a) may be proved with direct or circumstantial evidence.
Greer v. Cummins Inc. · filed 2022-07-01(a)
While a plaintiff may prove a race discrimination claim under Title VII and Section 1981 with either direct or circumstantial evidence, the same analysis governs both statutory provisions.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires facts that plausibly connect an adverse employment action to the employee’s race.
Cennington v. Austin · filed 2022-07-21(a)(1)
Plaintiff has not provided any facts that allow racial motivation to be inferred from any of the aforementioned actions. Accordingly, plaintiff has failed to state a Title VII racial discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; an employer’s honest belief that an employee violated its policy can defeat an inference of discriminatory intent.
Sims v. Washington Metropolitan Area Transit Authority · filed 2022-08-11(a)(1)
In any event, the “appropriate question” is not whether the policy expressly covers Sims’s conduct, but whether WMATA “honestly believed” Sims violated the policy such that it could not be said to have acted with discriminatory intent.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a) must plausibly allege replacement by someone outside the plaintiff’s protected group or less favorable treatment than similarly situated employees outside that group.
Hood v. Gulf Capital Bank, Inc. · filed 2022-08-22(a)
He has not alleged that he was replaced by someone outside his protected group or was treated less favorably than other similarly situated employees outside the protected group.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; a plaintiff relying on indirect evidence must establish a prima facie case and show that the employer’s stated reason was a pretext for discrimination.
Adams v. Cottage Care · filed 2022-09-12(a)(1)
The Court determines on the record evidence before it, even with all reasonable inferences drawn in Ms. Adams’ favor, no reasonable juror could conclude that Ms. Adams can establish a prima facie case of racial discrimination. Furthermore, even if Ms. Adams could establish a prima facie case, on the record evidence before the Court she fails to show that a reasonable juror could conclude that Cottage Care’s actions were a pretext for racial discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; an employee must present evidence that could permit a reasonable factfinder to connect an adverse employment action to race.
Graham v. Caterpillar · filed 2022-09-13(a)(1)
The Court finds that Plaintiff has failed to identify facts to establish that he suffered racial discrimination, as he has failed to sustain his burden as to the second and fourth elements under McDonnell Douglas.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) can survive dismissal when the complaint plausibly alleges protected status, an adverse employment action, qualification, and less favorable treatment.
Wooley v. Indigo Ag, Inc. · filed 2022-09-21(a)(1)
Applying the McDonnell Douglas framework to the allegations in Mr. Wooley’s Complaint, the Court finds that Mr. Wooley has alleged sufficient facts to state a plausible claim for racial discrimination.Read the full opinion on CourtListener →
Evidence that a similarly situated employee of another race received lesser discipline for the same conduct can create a genuine dispute over whether an employer’s stated reason was a pretext for race discrimination.
Bryant v. Mayorkas · filed 2022-09-22(a)(1)
Because the Court finds a reasonable jury could conclude Plaintiff was treated less favorably than Justin for the same conduct, there is a genuine issue of fact regarding pretext that precludes summary judgment in favor of either party on Plaintiff’s discrimination claim.Read the full opinion on CourtListener →
Allegations of protected status and satisfactory job performance satisfy the first two prima facie elements of a Title VII race discrimination claim.
Brown v. Secretary of the Army · filed 2022-09-23(a)(1)
In this case, Brown asserts factual allegations that satisfy the first two elements of a prima facie case of discrimination based on race: (1) he is African American, and (2) he started his position at the Army Reserves in 2011, and has since received excellent performance reviews, step increases, and awards.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race or color discrimination claim to allege facts supporting a plausible inference that an adverse employment action was discriminatory.
Brown v. McDonough · filed 2022-09-30(a)(1)
Plaintiff therefore has failed to allege a Title VII discrimination claim based upon race or color upon which relief can be granted.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a racial termination claim to plausibly connect the termination to race; allegations of discriminatory remarks alone do not suffice.
Bright v. Argos Cement USA, LLC · filed 2022-10-05(a)(1)
Although Mr. Bright’s amended complaint alleges Mr. Warren made several derogatory and racially discriminatory statements to Mr. Bright, it does not allege that race was the basis for Mr. Bright’s termination. The allegations in Mr. Bright’s amended complaint are not enough to support an inference beyond the speculative level that Mr. Bright has a right to relief for his race discrimination claims.Read the full opinion on CourtListener →
Section 2000e-2 prohibits an employer from discharging an employee because of race; a claim requires evidence from which a reasonable jury could find that race caused the discharge.
Earl v. Jewel Food Stores Inc · filed 2022-10-05(a)
Earl has not raised a triable issue as to whether he was terminated because of his race, and summary judgment in Jewel’s favor on Counts I and II is proper.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires evidence from which a reasonable jury could find that race caused an adverse employment action.
Tolliver v. Marine Credit Union · filed 2022-10-06(a)(1)
To defeat summary judgment on his discrimination claim, Tolliver needs to submit evidence from which a reasonable juror could conclude that MCU fired him because of his race. ... Tolliver has failed to put forth evidence on which a rational trier of fact could find for him on his discrimination claims. Thus, summary judgment is granted in favor of MCU.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to proceed when an employee plausibly alleges that the employer fired him while retaining white employees who breached the same workplace rules.
Reddick v. A.O. Smith Corporation · filed 2022-10-27(a)(1)
Title VII makes it unlawful for an employer to discharge any individual “because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). ... Accepting these factual allegations as true, as it must at this stage, the Court concludes Plaintiff's complaint plausibly states a claim for Title VII race discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) race discrimination claims are analyzed under the same framework as section 1981 employment discrimination claims.
PATEL v. CF FRESH LLC · filed 2022-11-07(a)(1)
Title VII and section 1981 employment discrimination claims are analyzed in the same way.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a race discrimination claim to proceed when an employee plausibly alleges that an employer denied promotions because of race.
Bass v. Union Pacific Railroad Company · filed 2022-11-15(a)(1)
Bass has pled enough to state a plausible cause of action and has pled enough facts “to provide the defendant with sufficient notice to begin to investigate and prepare a defense.” Tamayo, 526 F.3d at 1084; Samovsky v. Nordstrom, Inc., 619 F. App'x 547, 548 (7th Cir. 2015).Read the full opinion on CourtListener →
A race discrimination claim requires facts supporting satisfactory job performance and an adverse employment action based on race.
Shomo v. North American Partners in Anesthesia · filed 2022-12-06(a)(1)
Because the Complaint has not sufficiently alleged that plaintiff was satisfactorily performing her job or that she suffered an adverse employment action based on her race, her claim for race-based discrimination will be dismissed.Read the full opinion on CourtListener →
A plaintiff sufficiently pleads a Title VII race discrimination claim by alleging that her employer took adverse action because of her race; she need not plead facts sufficient to survive summary judgment.
HOBBS v. FEDEX GROUND PACKAGE SYSTEM, INC. · filed 2022-12-06(a)(1)
But Ms. Hobbs' allegations are enough at the motion to dismiss stage to sufficiently allege Title VII and § 1981 race discrimination claims.Read the full opinion on CourtListener →
A race discrimination claim under § 2000e-2(a)(1) can survive dismissal when allegations of termination, replacement by a less experienced white employee, and racially charged conduct plausibly suggest discriminatory treatment.
Edwards v. Maryland Crime Victims' Resource Center, Inc. · filed 2022-12-07(a)(1)
Under Title VII, it is unlawful for an employer “to discriminate against any individual with respect to his [or her] 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). ... The Court finds that Ms. Edwards has presented plausible allegations of race discrimination. ... The Motion is thus denied as to Counts I, II, and III.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race discrimination complaint to plausibly allege an adverse employment action caused by intentional race discrimination.
Jackson v. Huckaby Automotive · filed 2022-12-08(a)(1)
So as long as a plaintiff’s well-pleaded factual allegations plausibly suggest that she suffered an adverse employment action because of intentional race discrimination, she has stated a claim of race discrimination under Title VII.Read the full opinion on CourtListener →
Race discrimination claims under Section 2000e-2(a)(1) are analyzed the same way as employment discrimination claims under Section 1981 and the PHRA.
EVANS v. SCHOOL DISTRICT OF PHILADELPHIA · filed 2022-12-13(a)(1)
Race-based employment discrimination claims under Title VII, section 1981, and the PHRA are analyzed in the same way.Read the full opinion on CourtListener →
A Title VII race discrimination complaint plausibly alleges replacement outside the protected class when it alleges that a white employee replaced a Black employee.
Southall v. Ford Motor Company · filed 2022-12-09(a)(1)
In doing so, he alleges that Ford replaced him with someone outside of his protected racial class. This suffices for his race discrimination claim.Read the full opinion on CourtListener →
A race discrimination complaint under § 2000e-2 must allege facts supporting a reasonable expectation that discovery will reveal the necessary elements of the claim.
LEWIS v. JUNIPER NURSING · filed 2023-01-23
Here, Plaintiff does not allege any of the elements of a prima facie case of race discrimination, nor does he allege enough facts to raise a reasonable expectation that discovery would reveal evidence of such elements.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) bars employment decisions based on race or sex; a claim fails when the employer gives legitimate reasons and there is no evidence either trait influenced its decisions.
Hrdlicka v. General Motors, LLC · filed 2023-02-07(a)(1)
There is no evidence that sex or race had any influence on these decisions. The claims therefore lack merit.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a complaint must allege facts supporting an inference of discrimination based on race.
Brown v. NE Book Company · filed 2023-02-09(a)(1)
Even construed liberally, these allegations do not support a reasonable inference that Defendants are liable for racial discrimination, nor do they provide fair notice of the nature and basis or grounds for Plaintiff’s discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; circumstantial evidence must permit a reasonable inference of discriminatory intent to sustain a claim.
Key v. Dynamic Security, Inc. · filed 2023-02-10(a)(1)
Title VII prohibits discrimination on the basis of race. 42 U.S.C. § 2000e-2(a)(1). ... This circumstantial evidence, however, does not demonstrate a convincing mosaic of racial discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employers from discriminating in employment because of race or color.
Johnson v. Accenture LLP · filed 2023-02-14(a)(1)
Similarly, Title VII of the Civil Rights Act of 1964 prohibits employers from discriminating with respect to the termination, compensation, terms, conditions, or privileges of employment because of a person’s race or color.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in compensation and other terms of employment; a Title VII plaintiff must show that race was a motivating factor in the challenged decision.
TYLER v. CAPSTONE LOGISTICS, LLC · filed 2023-02-15(a)(1)
With respect to causation, Title VII requires the plaintiff to show that his race was "a motivating factor in the defendant's challenged employment decision." Comcast, 140 S. Ct. at 1017.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits firing an employee because of race; a wrongful termination claim can proceed when the alleged facts plausibly connect race to the firing.
Hill v. Envoy Air Inc. · filed 2023-02-16(a)(1)
Title VII of the Civil Rights Act of 1964 and the Kentucky Civil Rights Act make it illegal for an employer to fire or discriminate against someone because of that person’s race. ... Hill has pled sufficient facts for the Court, in its “judicial experience and common sense[,]” to infer a plausible claim that Hill was fired because of his race.Read the full opinion on CourtListener →
Section 2000e-2 prohibits discrimination based on race or sex in an employee’s compensation, terms, conditions, or privileges of employment.
Gaines v. Baltimore City, Maryland · filed 2023-02-22(a)(1)
Title VII prohibits an employer, inter alia, from discriminating against “any individual with respect to [her] 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; see Wormuth, 54 F.4th at 210; Roberts v. Glenn Industrial Group, Inc., 998 F.3d 111, 117 (4th Cir. 2021).Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race-based discharge; when an employer offers a legitimate reason, the employee must present evidence from which a factfinder could find that reason pretextual.
WRIGHT v. UNIVERSITY OF PENNSYLVANIA HEALTH SYSTEM · filed 2023-03-01(a)
Under Title VII, it is 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 . . . .” 42 U.S.C. § 2000e-2(a). ... Except for Plaintiff’s bald assertions, Plaintiff offers no evidence “from which a fact-finder could reasonably disbelieve the employer’s articulated legitimate reasons”.Read the full opinion on CourtListener →
A Title VII refusal-to-hire claim based on race must allege facts supporting a reasonable inference that the employer denied the applicant a job because of race.
Emrit v. University of Miami School of Law · filed 2023-03-06(a)(1)
Count IX fails for the same reason. Title VII makes it 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). Here, Plaintiff alleges he was denied employment on the basis of his race, ECF No. [1] ¶¶ 32, 59, but ... alleges no facts for the Court to draw the reasonable inference that Defendants denied Plaintiff employment on the basis of his race.Read the full opinion on CourtListener →
A race discrimination plaintiff establishes a prima facie case by showing an adverse employment action under circumstances supporting an inference of racial discrimination.
Brown v. PETCO Animal Supplies Store, Inc. Store 1827 · filed 2023-03-06(a)(1)
Brown has satisfied his burden in making a prima facie case of employment discrimination based on race.Read the full opinion on CourtListener →
A race discrimination claim based on denied reclassification can survive dismissal when the alleged facts plausibly suggest race played a role in the decision.
SCOTT v. MACON BIBB COUNTY GEORGIA · filed 2023-03-08(a)(1)
The Court finds these facts sufficiently allege that race played some role in the defendants’ decision not to reclassify Scott as an Appraiser III.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits discharge because of race; allegations that an employer treated Black employees more harshly than white employees during layoffs can support a plausible disparate treatment claim.
Renibe v. University of Maryland College Park · filed 2023-03-21(a)(1)
The alleged contrast between the layoffs of African American and Caucasian employees—and in particular, the hostile manner in which Plaintiff and his African American co-workers were treated—is enough to support a reasonable inference that Plaintiff faced discrimination because of race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits employment decisions based on race or sex; a claim fails when the employer gives legitimate reasons for its decisions and there is no evidence that either trait influenced them.
Hrdlicka v. General Motors, LLC · filed 2023-03-23(a)(1)
Title VII applies when an employer attempts 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 or sex. 42 U.S.C. § 2000e-2(a)(1). ... There is no evidence that sex or race had any influence on these decisions. The claims therefore lack merit.Read the full opinion on CourtListener →
A Title VII race discrimination plaintiff relying on comparator evidence must show that similarly situated employees outside the plaintiff’s class were treated more favorably.
Lowe v. Pettway · filed 2023-03-28(a)
Because Mr. Lowe has not satisfied the fourth element of his prima facie case, he cannot establish discriminatory intent using the McDonnell Douglas framework.Read the full opinion on CourtListener →
Section 2000e-2 requires a racial discrimination claim to connect an adverse employment action to the employee’s race.
Ellis v. Goodheart Specialty Meats · filed 2023-03-20
Plaintiff failed to show that she was terminated because of her race. Instead, her pleadings allege that she was terminated because of an unrelated back injury.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment, and a qualified worker plausibly states a claim by alleging that his employer replaced him with less qualified workers outside his protected class.
Maluf v. Bergelectric Corp · filed 2023-03-30(a)(1)
He alleges that he was replaced by individuals who were less qualified and were not Argentine. Plaintiff has stated a plausible claim at this stage for racial discrimination in violation of Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a denied-promotion race discrimination claim to proceed when the evidence would permit a reasonable jury to find that race caused the denial.
Greer-Medley v. Board of Trustees SIU · filed 2023-03-31(a)(1)
Viewed as a whole, the record permits a reasonable jury to conclude that Plaintiff's race caused the denial of her promotion to full Professor.Read the full opinion on CourtListener →
Section 2000e-2(m) prohibits using race as a motivating factor in an employment practice, and a claim requires facts supporting an inference of intentional discrimination.
Jackson v. Clinic Security & Logistics Inc. · filed 2023-03-31(m)
Title VII imposes a lower burden for race discrimination claims than § 1981, prohibiting an employer from using an employee’s race as a “‘motivating factor for any employment practice.’” ... Desert Palace, Inc. v. Costa, 539 U.S. 90, 101 (2003) (quoting 42 U.S.C. § 2000e-2(m)). But Jackson’s conclusory allegations do not satisfy this standard either.Read the full opinion on CourtListener →
A plaintiff’s subjective belief that race caused his termination, without supporting facts, is insufficient to state a Title VII race discrimination claim.
Johnson v. Original Chopshop · filed 2023-04-27(a)(1)
A plaintiff's own subjective belief that he was terminated because of his race is a legal conclusion that does not suffice to prevent a motion to dismiss.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits race discrimination in employment; a plaintiff challenging an employer’s stated reason for termination must offer evidence from which a factfinder could infer racial discrimination.
HOOKS v. VA PITTSBURGH HEALTHCARE SYSTEM · filed 2023-05-03(a)(1)
While Plaintiff has attempted to undermine VAPHS’s stated reasons for the termination of his employment, he has adduced no evidence from which a fact finder could conclude that VAPHS’s decision to terminate his employment was motivated by a discriminatory racial animus.Read the full opinion on CourtListener →
Notes 4201–4350 of 12,593, oldest cases first.
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