Background
Susan Plott Stokes appealed a district court order granting defendants’ motions to dismiss her complaint. Stokes alleged that her employment was terminated because of her gender in violation of Title VII of the Civil Rights Act of nineteen sixty-four. The case originated in the United States District Court for the Eastern District of Virginia.
The court’s reasoning
The court reviewed the record and found no reversible error. The opinion cites Johnson v. Baltimore City, Md., to establish that a claim of discrimination in the enforcement of employee disciplinary measures requires that the plaintiff’s prohibited conduct was comparable in seriousness to the misconduct of employees outside the protected class. The court further noted that the perception of the decision maker is relevant in determining whether discipline is justified, not the self-assessment of the plaintiff.
We have reviewed the record and find no reversible error.
Stokes v. AMF Bakery Sys., No. 25-2158 (4th Cir. May 26, 2026)
What it means going forward
The decision reinforces the requirement that plaintiffs in employment discrimination cases must provide specific evidence that comparators outside their protected class engaged in misconduct of comparable seriousness.
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