Sanders v. Christwood, No. 19-30550 (5th Cir. 2020)
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Plaintiff challenged the district court's summary judgment dismissal of her action for intentional discrimination under 42 U.S.C. 1983 and Title VII of the Civil Rights Act of 1964, as well as retaliation under Louisiana's Whistleblower Statute (LWS).
The Fifth Circuit affirmed the district court's dismissal of plaintiff's discrimination claims, rejecting plaintiff's claim of intentional discrimination rooted in Christwood's failure to timely list her with the state as a director, claim of discriminatory pay, claim of discriminatory demotion, and claim of constructive discharge. The court reversed the district court's dismissal of plaintiff's whistleblower claim, holding that Christwood was plaintiff's employer. Because the district court concluded that Christwood was not an employer, it failed to address the remainder of plaintiff's LWS claim. Therefore, the court vacated the dismissal of the LWS claim and remanded for further consideration.
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