Race Discrimination

Listen to this article

7^th Circuit Court of Appeals

Case Name: Chris P. Lane v. Riverview Hospital

Case No.: 15-1118

Officials: MANION, WILLIAMS, and HAMILTON, Circuit Judges.

Focus: Race Discrimination

No error on behalf of the court in granting summary judgment for defendants. Appellant intentionally injured a patient, yielding a reasonable termination.

“If there were more substance to the Rainey comparison here, we would find a jury issue here, as well. But the two inferential steps go too far here. To go from this factual discrepancy to an inference of racial bias, a jury would have to conclude first that the discrepancy was the result of a deliberate decision to mislead the EEOC and second that the motive of the deliberate decision to mislead was to conceal unlawful race discrimination. Without further circumstantial evidence of unlawful discrimination, a reasonable jury could not take that step. (The issue here is familiar as the pretext element of the McDonnell Douglas framework for circumstantial evidence. See Castro, 786 F.3d at 574; McInnis v. Alamo Community College Dist., 207 F.3d 276, 283 (5th Cir. 2000). Even under that framework, such evidence of pretext is not enough by itself to prove discrimination; it becomes a factor only after the plain‐ tiff has shown other circumstances corroborating unlawful in‐ tent, including evidence that a similarly situated employee outside the plaintiff’s protected class was treated better. That additional evidence is missing here.) Even if we assume that Kuzee and the hospital deliberately misled the EEOC about her role in the Rainey incident, that would not by itself sup‐ port the further inference of unlawful intent. And the rest of the support here is just too weak to allow a reasonable inference of discrimination.”

Affirmed

Full Text

Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.