Carter v. Atrium Hospitality, No. 20-1192 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's grant of summary judgment to Atrium in an action brought by plaintiff, a former employee, alleging race discrimination, failure to promote, and hostile work environment in violation of the Iowa Civil Rights Act (ICRA). Absent further instruction from the Iowa Supreme Court to the contrary, the court will continue to apply the McDonnell Douglas framework to ICRA discrimination claims at summary judgment.
Under the McDonnell Douglas framework, the court concluded that plaintiff failed to present evidence of any situation in which a white Atrium employee took a hotel room out of service, made a key to it, and then allowed unregistered guests to gain possession of the key, without being fired as a result. Furthermore, there is no evidence of white Atrium employees engaging in comparably serious misconduct without experiencing similarly harsh employment consequences. Therefore, the court concluded that plaintiff has not shown that similarly situated employees outside of his protected class were treated more favorably than him after engaging in similar misconduct. The court also concluded that summary judgment on the failure to promote claim was warranted where plaintiff failed to present evidence showing that Atrium's stated reason for declining to promote him was pretextual. Finally, plaintiff's hostile work environment claim failed because he failed to show that he experienced the workplace as abusive or that he felt that the harassment was so severe that it in effect altered the terms of his employment.
Court Description: [Kelly, Author, with Smith, Chief Judge, and Erickson, Circuit Judge] Civil case - Employment discrimination. Absent further instruction from the Iowa Supreme Court, the court will apply the McDonnell Douglas framework to claims under the Iowa Civil Rights Act; plaintiff's race discrimination claim failed because the plaintiff had not presented evidence that the context of his termination warranted an inference of discrimination, and the district court did not err in granting summary judgment for the employer; with respect to whether plaintiff made a prima facie case of race discrimination on his failure-to-promote claim, plaintiff failed to show the legitimate, non-discriminatory reasons the employer provided for selecting other candidates were pretexts for race discrimination; on plaintiff's hostile work environment, plaintiff failed to show that the complained-about conduct was so abusive or severe that it in effect altered the terms of his employment, and the district court did not err in granting the employer summary judgment on the hostile work environment claim.
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