Collins v. K.C. MO Public School District, No. 23-2182 (8th Cir. 2024)
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The case involves Albert Collins, who was employed by the Kansas City Missouri Public School District. After the termination of his employment, Collins sued the school district, alleging racial discrimination and retaliation for participating in protected activities. The school district had fired Collins following an investigation into "attendance fraud," a scheme in which Collins admittedly took part. The three claims relevant in this case were racial discrimination during termination in violation of Title VII and 42 U.S.C. § 1983, retaliation for engaging in protected activities under Title VII and § 1983, and violation of a state law prohibiting public employers from retaliating against whistleblowers.
The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision to grant summary judgment in favor of the school district. The court held that Collins failed to provide sufficient evidence for a reasonable jury to conclude that his termination was motivated by his race. He failed to demonstrate that a white employee engaged in the same fraudulent scheme was treated differently, failing to meet the "rigorous" requirement that the comparators must have dealt with the same supervisor, been subject to the same standards, and engaged in the same conduct.
The court also found that Collins' retaliation claim failed for lack of evidence linking his termination to any protected conduct. His interviews about the attendance fraud scheme were not related to race, and he failed to demonstrate that another employee's claims, in which he acted as a witness, had anything to do with racial discrimination or retaliation.
Regarding the whistleblower claim, the court held that a Missouri law excluding disclosures related to the employee's own violations applied to Collins. Since he failed to argue against the court's application of the statutory exclusion, his challenge to the court's grant of summary judgment on his whistleblower claim was deemed waived.
Court Description: [Arnold, Author, with Loken and Stras, Circuit Judges] Civil case - Employment discrimination. The circumstances of plaintiff's termination show that the school district had a legitimate, non-discriminatory ground for termination - plaintiff had altered student attendance records - which plaintiff failed to show was a pretext for race discrimination; plaintiff's retaliation claim failed to show it was related to a protected activity; plaintiff failed to offer any meaningful argument on his claim that the district court erred by applying an exclusion in the Missouri Whistleblower Act and he has thereby waived the issue.
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