Fields v. Shelter Mut. Ins. Co.
In Fields v. Shelter Mut. Ins. Co., 2008 U.S. App. LEXIS 6136, 102 Fair Empl. Prac. Cas. (BNA) 1652 (8th Cir. Ark. Mar. 25, 2008), the Court of Appeals for the Eighth Circuit set forth the test for a Title VII employment discrimination claim and affirmed summary judgment against the employee.
In the case employee Fields alleged that employer Shelter treated her differently than its Caucasian employees with respect to her pay. Shelter moved for summary judgment on both claims, and the district court granted Shelter's motion. In doing so, the district court held that Fields failed to establish a prima facie case of race discrimination because she failed to adduce evidence that Shelter treated similarly situated employees differently.
The Eighth Circuit affirmed. It first stated that:
- In race discrimination cases, a plaintiff may survive a defendant's motion for summary judgment in one of two ways. The plaintiff may present admissible evidence directly indicating unlawful discrimination, that is, evidence showing a specific link between the alleged discriminatory animus and the challenged decision, sufficient to support a finding by a reasonable fact finder that an illegitimate criterion actually motivated the adverse employment action. Russell v. City of Kan. City, Mo., 414 F.3d 863, 866 (8th Cir. 2005). Alternatively, if the plaintiff lacks such evidence of discrimination, she may survive the defendant's motion for summary judgment by creating an inference of unlawful discrimination under the burden-shifting framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-04, 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1973).
Then the Court stated that:
- Under the McDonnell Douglas framework, the plaintiff bears the burden of establishing a prima facie case of discrimination. McGinnis v. Union Pac. R.R., 496 F.3d 868, 873 (8th Cir. 2007). To meet her burden, a plaintiff must show the following: (1) that she is a member of a protected class; (2) that she was meeting her employer's legitimate job expectations; (3) that she suffered an adverse employment action; and (4) that similarly situated employees outside the protected class were treated differently. Carpenter v. Con-Way Cent. Express, Inc., 481 F.3d 611, 616 (8th Cir. 2007).
The Court found that the facts did not support that "similarly situated" employees outside the plaintiff's class were treated differently.