Maria Murguia v. Charisse Childers, No. 22-2831 (8th Cir. 2023)
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Plaintiff sued the Director of the Arkansas Division of Workforce Services (“DWS”) in her official capacity, alleging discrimination on the ground of national origin under Title VI of the Civil Rights Act. The district court entered summary judgment in favor of the Director.
The Eighth Circuit affirmed. Plaintiff insists her prima facie case is strong enough to establish pretext. However, the court wrote that even if Plaintiff had presented a prima facie case of intentional discrimination, she has nonetheless failed to carry her burden under McDonnell Douglas of showing the reasons for her bureaucratic troubles were a pretext for intentional discrimination. Plaintiff also argued the district court erred by rejecting her alternative request to apply a deliberate indifference standard when analyzing her Title VI claim. However, the court wrote that even assuming for the sake of argument that the deliberate indifference standard applies, in light of the court’s conclusion under McDonnell Douglas, Plaintiff fails to raise a genuine issue of material fact under the “high standard” of deliberate indifference.
Court Description: [Grasz, Author, with Gruender and Kelly, Circuit Judges] Civil case - Civil Rights Act. Plaintiff, a Mexican national, alleged the Arkansas Division of Workforce Services discriminated against her on the basis of national origin in violation of Title VI of the Civil Rights Act in the handling of her claim for unemployment insurance during the pandemic; in the absence of direct evidence, the claim must be evaluated under the McDonnell Douglas framework; plaintiff failed to establish a prima facie case of intentional discrimination based on the agency's failure to provide language access to her as a Spanish speaker; even if plaintiff presented a prima facie case of intentional discrimination, operational changes associated with the early months of the pandemic provided a legitimate, nondiscriminatory basis for plaintiff's bureaucratic troubles obtaining unemployment insurance, and plaintiff failed to establish the reasons were pretexts; a deliberate indifference standard did not apply in this context. Judge Kelly, dissenting.
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