Background
Savannah Moton sued her former employer, Amer Sports, alleging she was fired due to her race and in retaliation for filing an internal complaint about discrimination. The district court granted summary judgment to Amer Sports, finding Moton lacked sufficient evidence to prove her claims. Moton appealed the decision.
The court’s reasoning
The Sixth Circuit reviewed the grant of summary judgment de novo. For the race discrimination claim, the court found Moton failed to establish a prima facie case because she could not identify a similarly situated non-protected employee who was treated more favorably. The court rejected Moton’s argument that inconsistencies regarding who made the termination decision proved pretext, noting that pretext analysis only applies after a prima facie case is established. For the retaliation claim, the court held that temporal proximity alone was insufficient to prove causation. The record showed Amer Sports had previously contemplated terminating Moton for performance issues before she filed her complaint, and the termination proceeded along those same lines.
Because Moton can’t establish a prima facie case for either discrimination or retaliation, the district court correctly granted summary judgment to Amer.
What it means going forward
Employers may rely on documented performance issues to justify termination even if a discrimination complaint was filed shortly before, provided the decision to terminate was contemplated prior to the complaint.
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