RONALD HITTLE V. CITY OF STOCKTON, ET AL, No. 22-15485 (9th Cir. 2023)
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Plaintiff alleged that he was terminated from his position as Fire Chief for the City of Stockton based on his religion and, specifically, his attendance at a religious leadership event.
The Ninth Circuit affirmed the district court’s summary judgment in favor of Defendants in Plaintiff’s employment discrimination action under Title VII and California’s Fair Employment and Housing Act. The panel held that, in analyzing employment discrimination claims under Title VII and the California FEHA, the court may use the McDonnell Douglas burden-shifting framework, under which plaintiff must establish a prima facie case of discrimination. The burden then shifts to the defendant to articulate a legitimate, nondiscriminatory reason for the challenged actions. Finally, the burden returns to Plaintiff to show that the proffered nondiscriminatory reason is pretextual. Alternatively, Plaintiff may prevail on summary judgment by showing direct or circumstantial evidence of discrimination.
The court explained that Plaintiff was required to show that his religion was “a motivating factor” in Defendants’ decision to fire him with respect to his federal claims and that his religion was “a substantial motivating factor” with respect to his FEHA claims. The panel concluded that Plaintiff failed to present sufficient direct evidence of discriminatory animus in Defendants’ statements and the City’s notice of intent to remove him from City service. And Plaintiff also failed to present sufficient specific and substantial circumstantial evidence of religious animus by Defendants.
Court Description: Employment Discrimination The panel affirmed the district court’s summary judgment in favor of defendants in Ronald Hittle’s employment discrimination action under Title VII and California’s Fair Employment and Housing Act.
Hittle alleged that he was terminated from his position as Fire Chief for the City of Stockton based upon his religion and, specifically, his attendance a religious leadership event.
The panel held that, in analyzing employment discrimination claims under Title VII and the California FEHA, the court may use the McDonnell Douglas burden- shifting framework, under which the plaintiff must establish a prima facie case of discrimination. The burden then shifts to the defendant to articulate a legitimate, nondiscriminatory reason for the challenged actions. Finally, the burden returns to the plaintiff to show that the proffered nondiscriminatory reason is pretextual. Alternatively, the plaintiff may prevail on summary judgment by showing direct or circumstantial evidence of discrimination. Hittle was required to show that his religion was “a motivating factor” in defendants’ decision to fire him with respect to his federal claims, and that his religion was “a substantial motivating factor” with respect to his FEHA claims.
The panel concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in defendants’ statements and the City’s notice of intent to remove him from City service. And Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by defendants. The district court’s grant of summary judgment in defendants’ favor was appropriate where defendants’ legitimate, non- discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual.
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