Stone v. McGraw-Hill Global Financial, No. 15-3299 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit against McGraw-Hill, alleging claims of employment discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 1981, and the Missouri Human Rights Act. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of McGraw-Hill, holding that plaintiff failed to show a pretext for discrimination on his claim that two white counterparts were paid a higher salary; plaintiff failed to establish a case of salary discrimination on his claim that he was denied a spot bonus where no similarly situated employee was treated differently; in regard to the hostile work environment claim, plaintiff failed to show a causal connection between the alleged acts of harassment and his race; one race-related comment that plaintiff allegedly overheard did not constitute harassment sufficiently severe and pervasive to support a hostile work environment claim; and, in regard to the discriminatory discharge claim, even if plaintiff established a prima facie case of discriminatory discharge, he did not meet his burden to show that McGraw-Hill's proffered reason for discharging him was pretext for discrimination. In this case, plaintiff's documented performance deficiencies constituted a legitimate, nondiscriminatory reason for discharging him. Finally, any claim of retaliation failed because plaintiff failed to show a causal connection between the alleged retaliatory act and protected conduct.
Court Description: Wollman, Author, with Smith, Chief Judge, and Benton, Circuit Judge] Civil case - Employment discrimination. The district court correctly held that even if plaintiff could establish a prima facie case of discrimination based on the fact that two white counterparts were paid a higher starting salary, he had failed to show that defendant's stated reasons for the salary disparities were a pretext for discrimination based on his race; plaintiff failed to establish a prima facie case of salary discrimination based on the denial of a bonus as he identified no similarly situation employee who was treated differently; with respect to plaintiff's hostile work environment claim, the district court correctly held that plaintiff failed to show a causal connection between the alleged acts of harassment and his race; one race-related comment did not constitute harassment sufficiently severe and pervasive to support a hostile work environment claim; even if plaintiff established a prima facie case of discriminatory discharge, he failed to show the employer's stated performance-related grounds for the termination were a pretext for discrimination.
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