White v. North Louisiana Criminalistics Laboratory

Holding: The court affirmed the district court's judgment granting summary judgment because the plaintiff failed to establish a prima facie case of sex discrimination and could not prove pretext for retaliation.
Standard: McDonnell Douglas burden-shifting framework
Vote: Per Curiam opinion affirming the district court's grant of summary judgment.
Practical effect: The decision reinforces the requirement for plaintiffs in employment discrimination cases to provide specific evidence of similarly situated comparators and clear, actionable complaints to survive summary judgment.

The United States Court of Appeals for the Fifth Circuit affirmed the district court's grant of summary judgment in a sex discrimination and retaliation case. The court held that the plaintiff failed to establish a prima facie case of discrimination and could not prove that the employer's reasons for termination were pretextual.

Background

Carla White worked at the North Louisiana Criminalistics Laboratory from 2005 until her termination in 2020. After being promoted to interim supervisor, she faced performance issues, including tardiness, poor evidence handling, and a combative attitude. White alleged that she was fired due to sex discrimination and retaliation for complaining about her previous supervisor’s behavior. The district court granted summary judgment for the laboratory, finding White could not establish a prima facie case or prove pretext.

The court’s reasoning

The court applied the McDonnell Douglas burden-shifting framework. For the sex discrimination claim, White failed to satisfy the fourth element of the prima facie case because she was not replaced by someone outside her protected class and her proposed comparators were not similarly situated. For the retaliation claim, the court found White’s complaints were not clear enough to be protected activity. Even assuming a prima facie case existed, White failed to produce evidence that the laboratory’s legitimate reasons for termination were pretext. The court noted that the chronology of events showed her insubordination and misconduct were the but-for causes of her termination.

What it means going forward

The decision reinforces the requirement for plaintiffs in employment discrimination cases to provide specific evidence of similarly situated comparators and clear, actionable complaints to survive summary judgment.

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