Pribyl v. County of Wright, No. 18-3743 (8th Cir. 2020)
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Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA).
The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory.
Court Description: [Kelly, Author, with Loken and Benton, Circuit Judges] Civil case - Employment discrimination. In the absence of direct evidence of gender-based discrimination in defendant's decision not to promote plaintiff, the court would apply the McDonnell Douglas burden-shifting framework; as the defendant concedes the plaintiff made a prima facie case, the issue is whether defendant's proffered non-discriminatory reason for its decision - plaintiff's interview - was a pretext for discrimination; plaintiff failed to meet her burden to show pretext and the district court did not err in rejecting her cat's-paw theory.
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