Liles v. C.S. McCrossan, Inc., No. 15-3801 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit against CSM, alleging civil rights violations after she was terminated. The district court granted summary judgment to CSM. The court concluded that plaintiff failed to establish the causation element of her prima facie case of retaliation and reprisal based on the attenuated temporal proximity of the decline in her work performance and the her complaints, and the lack of evidence from which a jury could infer a discriminatory motive. Therefore, the district court properly granted summary judgment to CSM on these claims. The court also concluded that the district court properly dismissed plaintiff's gender discrimination claims where plaintiff had a history of satisfactory performance and the evidence demonstrated that her supervisors and coworkers had on numerous occasions informed her of perceived deficiencies in her work. Finally, the court concluded that the district court properly granted summary judgment to CSM on plaintiff's hostile work environment claim where she failed prove that the comments at issue were so objectively and subjectively offensive that they altered the terms and conditions of her employment. Accordingly, the court affirmed the judgment.
Court Description: Shepherd, Author, with Gruender and Beam, Circuit Judges] Civil case - Employment Discrimination. Plaintiff's complaints about discrimination against a fellow female employee and inappropriate conduct by a male co-worker were too distant in time to establish causation and retaliation for protected conduct; nor was there evidence from which a jury could infer a discriminatory motive and plaintiff could not establish the causation element of her prima facie case of retaliation and reprisal; with respect to her gender discrimination claim, the district court did not err in concluding that, assuming plaintiff made a prima facie case, defendant had established a legitimate, non-discriminatory ground for her discharge which plaintiff failed to show was a pretext for gender discrimination; with respect to plaintiff's hostile work environment claim, she failed to show that the harassment affected a term, condition or privilege of her employment.
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