Taffe v. Givaudan Flavors Corporation

Summary

In this Report and Recommendation, the magistrate judge recommends granting Givaudan Flavors Corporation’s motion for summary judgment in Henry George Taffe’s action alleging race discrimination and retaliation under 42 U.S.C. § 1981. The recommendation concludes that Taffe failed to establish a genuine issue of material fact and recommends denying the defendant’s spoliation-sanctions motion as moot.

Holdings

1. Summary judgment should be granted to Givaudan on Taffe's race-discrimination claim because he abandoned the claim in response to the motion and, independently, failed to present sufficient direct or indirect evidence that race was the but-for cause of any adverse employment action.
2. Summary judgment should be granted to Givaudan on Taffe's retaliation claim because Taffe could not establish that his protected activity was the but-for cause of the discontinuation of estimated overtime payments or his termination, and he could not show that Givaudan's stated reasons were pretextual.
3. The motion for sanctions for alleged spoliation should be denied as moot because summary judgment should be granted to Givaudan.

Questions Presented

1. Whether Givaudan was entitled to summary judgment on Taffe's § 1981 race-discrimination claim.
2. Whether Givaudan was entitled to summary judgment on Taffe's § 1981 retaliation claim based on discontinuing estimated overtime payments during continued leave and terminating his employment.
3. Whether Givaudan's motion for spoliation sanctions should be denied as moot after the recommended grant of summary judgment.

Disposition

other