Couch v. American Bottling Co., No. 18-3648 (8th Cir. 2020)
Annotate this CasePlaintiff filed suit alleging that Dr. Pepper retaliated against him for complaining about racial discrimination at the company. The Eighth Circuit affirmed the district court's grant of summary judgment to Dr. Pepper, holding that, even if plaintiff made a prima facie case of retaliation, Dr. Pepper provided legitimate nondiscriminatory reasons for its actions based on plaintiff's performance under the McDonnell Douglas burden-shifting framework. In this case, Dr. Pepper alleged that plaintiff had an inability to adjust to new management expectations, an unwillingness to be coached, and a refusal to sit through his interim performance review. The court also held that plaintiff failed to create a jury issue on pretext.
Court Description: [Stras, Author, with Loken and Grasz, Circuit Judges] Civil case - Employment discrimination. Plaintiff alleged defendant gave him a negative review, suspended him and then terminated him for filing a formal charge of discrimination against the defendant; as plaintiff had no direct evidence of retaliation, the court analyzes the claim under the familiar McDonnell Douglas framework; even if the court assumed plaintiff made a prima facie case of retaliation, defendant provided legitimate, non-discriminatory, performance-based grounds for its actions which plaintiff failed to show were pretexts; with respect to plaintiff's state-law based retaliation claim, he failed to meet his burden to show pretext, and his claim fails.
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