Summary
The Eighth Circuit affirmed summary judgment for UPS on claims of retaliation and discrimination under 42 U.S.C. § 1981. The retaliation claim failed because the plaintiff could not show a causal link between his protected activity and demotion, as the decision-makers were unaware of the activity and the temporal gap was too long. The discrimination claim failed because the plaintiff did not demonstrate pretext; UPS offered legitimate performance-based reasons for the demotion, and the plaintiff failed to identify a similarly situated comparator outside his protected class.
Topics
Practice areas
Questions Presented
- Whether the district court erred in granting summary judgment on Williams's retaliation claim under 42 U.S.C. § 1981.
- Whether the district court erred in granting summary judgment on Williams's race discrimination claim under 42 U.S.C. § 1981.
Key quotations
“We review a district court’s decision to grant summary judgment de novo.” (p. 4)
“a causal link does not exist if decision makers were unaware of the protected activity.” (p. 5)
“interval of more than two months is too long to support an inference of causation.” (p. 5)
“The comparator must be similarly situated in all relevant respects.” (p. 7)
Factual background
Cedric Williams, an African-American, was a District Labor Manager at UPS from 2004 to 2013. He had performance issues, including failure to maintain grievance logs, prepare for hearings, and communicate with supervisors. His supervisor, Richard Gough, placed him on a Management Performance Improvement Plan (MPIP) in April 2012. After Williams failed to meet MPIP goals, Gough and his supervisor Headley Chambers decided to demote Williams in January 2013. Williams's demotion did not reduce his salary but eliminated incentive opportunities. Williams had made statements in 2011 about consistency in disciplining African-American employees and gave a deposition in March 2012 in another employment discrimination case about UPS's treatment of African-American employees. Neither Gough nor Chambers knew about these activities. The demotion decision was ultimately approved by HR Director Stan Roux and District President Judy Henry, who were aware of the 2011 statements and 2012 deposition.
Procedural history
The district court granted summary judgment in favor of UPS on Williams's retaliation and discrimination claims under 42 U.S.C. § 1981. Williams appealed.