Haynes v. Waste Connections, Inc., No. 17-2431 (4th Cir. 2019)Annotate this Case
The Fourth Circuit reversed the district court's grant of summary judgment to WCI on all of plaintiff's claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The court held that the district court erred by finding that plaintiff, who is black, had failed to establish an appropriate comparator and to produce evidence of pretext. In this case, plaintiff produced evidence that a white employee with the same supervisor, who had several workplace infractions, was permitted to return to his job after the employee became angry and yelled at his supervisor before quitting. The court held that the record as a whole could permit a reasonable factfinder to conclude that plaintiff and that employee were proper comparators. Furthermore, plaintiff has produced evidence that WCI's reason for his termination has changed substantially over time, and therefore has presented sufficient evidence of pretext.