Background
Wanda J. Oden Meyers appealed pro se from a district court’s summary judgment in her employment discrimination action. She alleged violations of Title VII, the Rehabilitation Act of nineteen seventy-three, and the Genetic Information Nondiscrimination Act. The district court had granted summary judgment on her disparate treatment, retaliation, and hostile work environment claims.
The court’s reasoning
The court reviewed the case de novo and affirmed the district court’s decision. It held that the plaintiff failed to raise a genuine dispute of material fact as to whether the defendants’ legitimate, non-discriminatory, and non-retaliatory reasons for reassigning duties, placing her on a performance improvement plan, and recommending termination were pretextual. The court also found that the plaintiff failed to raise a triable dispute as to whether she was subjected to severe or pervasive verbal or physical conduct on the basis of race or disability sufficient to create an abusive working environment.
What it means going forward
The affirmation of summary judgment ends the plaintiff’s employment discrimination claims on appeal, leaving the district court’s ruling in favor of the employer in place.
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