Lightner v. Catalent CTS (Kansas City), No. 22-2452 (8th Cir. 2023)
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The United States Court of Appeals for the Eighth Circuit reviewed a case where Deborah Lightner, a former employee of Catalent CTS (Kansas City), LLC, alleged age discrimination and retaliation under Missouri law. Lightner had received multiple promotions during her employment, but after several employees left citing her management style, her performance was rated poorly. After raising concerns about age discrimination in an email, Catalent removed the option of a performance improvement plan (PIP), offering only a demotion or severance. The district court granted summary judgment in favor of Catalent.
Upon review, the Eighth Circuit affirmed the district court's decision on the age discrimination claim, as Lightner failed to show that Catalent's justifications were a pretext for discrimination. However, the court reversed the judgment on the retaliation claim. The court found that the timing of Catalent's removal of the PIP option within 48 hours of Lightner's complaint, combined with text messages from Catalent management, created a sufficient inference of retaliation. Here, the close temporal proximity was deemed sufficient to support a reasonable inference of a causal relationship. The case was remanded for further proceedings consistent with this opinion.
Court Description: [Grasz, Author, with Colloton and Kobes, Circuit Judges] Civil case - Employment discrimination. Plaintiff failed to show the reasons offered for her termination - a history of deficient performance in her current role - were pretexts for age discrimination; the minimal retirement discussions among plaintiff's managers were not so unnecessary or excessive as to raise an inference of age discrimination; however, the district court abused its discretion in denying plaintiff's motion to file a sur-reply after new evidence of management text messages was submitted after plaintiff filed her response to defendants' motion for summary judgment on her retaliation claim; considering the evidence, it was sufficient to support a reasonable inference of a causal relationship between the termination and plaintiff's age discrimination complaint, and the district court erred in granting defendants' motion for summary judgment; affirmed in part, reversed in part, and remanded for further proceedings.
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