Sandra Frierson v. SBC Global Services, No. 13-1900 (8th Cir. 2013)
Annotate this CaseCourt Description: Civil case - Employment Discrimination. The district court did not err in granting defendant's motion for summary judgment on plaintiff's claims she was retaliated against after she reported the race-based and gender-based harassment of a co-worker as there was no causal connection between any adverse employment action and plaintiff's protected activity.
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 13-1900 ___________________________ Sandra Frierson lllllllllllllllllllll Plaintiff - Appellant v. SBC Global Services, Inc. lllllllllllllllllllll Defendant - Appellee ____________ Appeal from United States District Court for the Western District of Missouri - Kansas City ____________ Submitted: December 23, 2013 Filed: December 30, 2013 [Unpublished] ____________ Before WOLLMAN, BYE, and KELLY, Circuit Judges. ____________ PER CURIAM. Sandra Frierson appeals the district court s1 adverse grant of summary judgment on her claim that her former employer retaliated against her, in violation of 1 The Honorable Ortrie D. Smith, United States District Judge for the Western District of Missouri. the Missouri Human Rights Act (MHRA) and 42 U.S.C. § 1981, after she reported the race-based and gender-based threatening and harassing conduct of a coworker, who was fired after an investigation. Frierson alleged that her job became more difficult after a reassignment of technicians she managed, her performance evaluations were not as favorable as they had been in the past, and she was told to stick it out rather than look for a different position within the company, before she was ultimately terminated pursuant to a reduction in force almost a year and a half after she reported the conduct of her coworker. Following careful review, we agree with the district court that Frierson did not establish a causal connection between any adverse employment action and her protected activity. See Olsen v. Capital Region Med. Ctr., 713 F.3d 1149, 1153 (8th Cir. 2013) (de novo review; to avoid summary judgment, non-movant must make sufficient showing on every essential element of her claim on which she bears burden of proof); Sayger v. Riceland Foods, Inc., 735 F.3d 1025, 1030-32 (8th Cir. 2013) (to show causal connection in § 1981 retaliation action, claimant must prove that employer s desire to retaliate was but-for cause of his or her termination); McCrainey v. Kansas City Mo. Sch. Dist., 337 S.W.3d 746, 753 (Mo. Ct. App. 2011) (prima facie MHRA retaliation claim requires proof that (1) claimant engaged in protected activity such as complaining about discrimination, (2) employer took adverse action against her, and (3) causal relationship existed between protected activity and adverse action). Accordingly, we affirm. See 8th Cir. R. 47B. ______________________________ -2-
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