Morrow v. Zale Corp., No. 15-2321 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against her former employer, alleging claims of gender discrimination under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment to defendants. The court concluded that there is a genuine issue of material fact as to whether Defendant John Daugherty was sufficiently involved in the decision to terminate plaintiff to qualify as a decision maker, given that the evidence showed that he participated in the investigation leading up to her termination, and that he was the one who ultimately told her she was terminated; there is a genuine issue of material fact as to whether Daugherty had earlier told plaintiff that she should step down because she was “a female” and “a single mom,” that it was “a man’s world,” and that she needed to “man up;" and because the court construed such comments, if made by a decisionmaker, as direct evidence of discriminatory animus, the court concluded, under a mixed-motive analysis, plaintiff may be entitled to some of the remedies she sought in her complaint. Accordingly, the court reversed and remanded.
Court Description: Per Curiam - Before Wollman, Arnold and Smith, Circuit Judges] Civil case - Employment discrimination. The record presented a genuine issue of material fact as to whether defendant Daugherty was sufficiently involved in the decision to terminate plaintiff to qualify as a decision maker; the evidence also presented a genuine issue of material fact as to whether he had told her that she should step down for reasons related to her gender and marital status; his comments, if made by a decision maker, would be direct evidence of a discriminatory animus, and under a mixed-motive analysis, plaintiff may be entitled to some of the remedies she sought in her complaint; defendant's summary judgment is reversed and the case remanded for further proceedings.
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