Huynh v. Dep't of Transp., No. 14-2785 (8th Cir. 2015)
Annotate this CaseAfter graduating from the FAA Academy, Huynh became a trainee air traffic controller. Huynh, the only Asian American in his training class, reported problems with his instructors. He was assigned a different team. The new team reported that Huynh was performing poorly. Huynh was granted 42 additional training hours above the180 target hours. After he completed those hours, Huynh moved on to the second of 12 required certifications. He was again reported as performing poorly. Huynh's team provided many opportunities to improve, beyond the 180t hours. Superiors reported that Huynh did not have command of basic air traffic terminology and geography and was defensive when trainers noted mistakes. Huynh was the only member of his class suspended for poor performance on a skill check. Huynh applied for reassignment, but no other facilities offered to hire him. A review board concluded that Huynh had been given comprehensive training, but had failed to progress. A manager nonetheless continued Huynh's training. Huynh received additional instruction and several weeks to refresh his learning. Shortly after Huynh returned to training, he reported problems with his supervisors and classmates. He declined reassignment. Problems continued; Huynh was terminated. The court granted the FAA summary judgment. The Eighth Circuit affirmed, rejecting claims of racial discrimination under 42 U.S.C. 2000e and the Minnesota Human Rights Act, finding that the stated reasons for termination were not pretextual.
Court Description: Murphy, Author, with Riley, Chief Judge, and Melloy, Circuit Judge] Civil case - Employment discrimination. Assuming plaintiff made a prima facie case that defendant fired him from his trainee air traffic controller position based on his race, the defendant established a legitimate, non-discriminatory ground for the termination (failure to master the necessary skills required of a controller), which plaintiff failed to show was a pretext for race discrimination.
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