Owens v. Circassia Pharmaceuticals, No. 21-10760 (5th Cir. 2022)
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Plaintiff alleged that her former employer, Circassia Pharmaceuticals (“Circassia”), fired her for discriminatory and retaliatory reasons. The district court granted summary judgment for Circassia, holding that Owens had failed to create a genuine dispute of material fact as to pretext.
The Fifth Circuit affirmed the district court’s grant of summary judgment for Defendant in Plaintiff’s employment discrimination lawsuit. The court held even when an employee presents evidence that would allow a jury to conclude that an employer’s proffered justification for an adverse action is false, that does not necessarily permit a rational inference that the real reason was discrimination Plaintiff provided enough evidence to permit a finding that Circassia’s proffered justification for her termination is false. But she has presented a mere scintilla of evidence that the true reason for her termination was discriminatory animus, and “the burden of proof [is hers] throughout.” The court held that summary judgment for Circassia is therefore appropriate because Plaintiff's evidence is of insufficient “nature, extent, and quality” to permit a reasonable factfinder to resolve “[t]he ultimate determination” of discrimination in her favor. Finally, the court reasoned that Plaintiff failed to raise additional arguments regarding pretext to support her retaliation claim, thus falling short of creating a genuine dispute of material fact.
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