Kristopher Adams v. Mark Pettway, in his official capacity as Sheriff of Jefferson County, Alabama, et al.

Summary

The United States District Court for the Northern District of Alabama granted summary judgment to Sheriff Mark Pettway and Deputy Chief Nashonda Howard in Kristopher Adams’s employment discrimination and retaliation action. The court held that Adams failed to establish discrimination under Title VII, 42 U.S.C. §§ 1981 and 1983, or the Equal Protection Clause, and failed to establish a prima facie retaliation claim. The court dismissed the case.

Holdings

1. Adams failed to establish a prima facie case of race discrimination because he did not identify a comparator who was similarly situated in all material respects and treated more favorably. He also failed to show that defendants' stated reason for selecting Harris was pretextual.
2. Adams failed to avoid summary judgment under the convincing-mosaic analysis because he presented insufficient evidence for a reasonable jury to infer intentional racial discrimination.
3. Adams's race-discrimination claims under §§ 1981 and 1983 and the Equal Protection Clause failed for the same reasons as his Title VII discrimination claim.
4. Adams failed to establish a prima facie case of Title VII retaliation because his mask-related complaint did not oppose race or another protected category, and his later race-discrimination complaint was filed nearly two months after the challenged transfer. He also failed to show pretext.
5. Adams's retaliation claims under §§ 1981 and 1983 failed because those claims use the same analytical framework as Title VII retaliation claims, under which Adams did not establish a prima facie case or pretext.
6. The Equal Protection Clause does not provide a freestanding claim for pure or generic retaliation, so Adams's Equal Protection retaliation claim failed as a matter of law.

Questions Presented

1. Whether Adams produced sufficient evidence of race discrimination under Title VII, §§ 1981 and 1983, and the Equal Protection Clause to survive summary judgment.
2. Whether Adams identified a similarly situated comparator or otherwise presented a convincing mosaic of circumstantial evidence of intentional race discrimination.
3. Whether Adams established a prima facie case of Title VII retaliation based on his complaints and transfer.
4. Whether Adams's § 1981 and § 1983 retaliation claims survived under the Title VII framework.
5. Whether the Equal Protection Clause recognizes a freestanding claim for retaliation.

Disposition

dismissed