Robinson v. American Red Cross, No. 13-2394 (8th Cir. 2014)
Annotate this CasePlaintiff appealed the district court's grant of summary judgment to the Red Cross on her claims, inter alia, of race discrimination and retaliation. The court concluded that plaintiff failed to establish a prima facie case of race discrimination based on the Red Cross' decision not to promote her and based on the failure to train her; the decision to suspend and terminate plaintiff was not a result of race discrimination but, rather, because plaintiff failed to meet her employer's legitimate expectations; even if plaintiff was able to show that she had met her employer's legitimate expectations, she failed to show that similarly situated employees committed the same conduct but were treated differently. The court concluded that the district court did not err in granting Red Cross summary judgment on the retaliation claim where plaintiff failed to establish a prima facie case of retaliation because plaintiff failed to raise a genuine issue of material fact to show a causal link between her protected activity and the adverse employment actions taken against her. Finally, the court concluded that the district court did not err in granting the Red Cross summary judgment on plaintiff's outrage claim.
Court Description: Civil Case - employment discrimination. District court's grant of summary judgment on race discrimination claim in failure to promote, failure to train, and termination are affirmed. By failing to oppose summary judgment on failure to promote, Robinson waived those claims. Robinson failed to establish a prima facie case of race discrimination for failure to hire for the On the Job Instructor position or for failure to train her. Because Robinson failed to meet her employer's legitimate expectations, she cannot establish a prima facie case that she was suspended or terminated because of her race. She also did not show that similarly situated employees were treated differently. Finally, she did not demonstrate a causal connection between her charge of discrimination and the adverse actions. The state law claim of outrage failed.
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