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cases/42usc1981/f3d-933-932-beasley-v-warren-unilube.case

Source: cases/42usc1981/f3d-933-932-beasley-v-warren-unilube.case

Case source: https://www.neochart.com/catalog/cases/f3d/volume_933/0932_01/index.html

Verbatim annotated passages

Because "[t]he same analysis [applies] to claims of discrimination ... under Title VII and 42 U.S.C. § 1981," Takele v. Mayo Clinic , 576 F.3d 834, 838 (8th Cir. 2009), we use Title VII as shorthand for both claims below.
Without some way to tie his termination to racial animus, Beasley's claim fails.
Because we find that Beasley has not established intentional discrimination, either by showing that Warren treated similarly-situated employees in a disparate manner or otherwise, his claims fail.

Exact source text

casedsl 1.2
# author: Flash2 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)

case /f3d/933/0932-01
  name    Beasley v. Warren Unilube, Inc.
  cite    933 F.3d 932 (2019)
  court   United States Court of Appeals for the Eighth Circuit
  date    2019-08-09
  url     catalog/cases/f3d/volume_933/0932_01/index.html
  source  ir/caselaw/f3d_933.jsonl sha1=f24d26b49eb88d6579814a0168573011e0d7ca18 chars=18706

opinion maj : majority by Kobes @0..18706 controlling

law 42usc1981
  role    applied
  posture civil; Title VII and Section 1981 discriminatory discharge; summary judgment for employer affirmed by CA8
  result  claimant-lost

element protected-person : satisfied [conceded]
  route   race
  pattern african-american
  fact @9509..9610 [supports] | He plainly meets the first and third requirements: he is a member of a protected group and was fired.

element own-contract : satisfied [conceded]
  route   employment-relationship
  pattern quality-assurance-manager
  fact @385..468 [supports] | Beasley started working as the Quality Assurance Manager at Warren in October 2012.

element private-actor : satisfied [conceded]
  route   _whole
  pattern manufacturing-employer
  fact @326..384 [supports] | Warren produces motor oil and other automotive lubricants.

element racial-intent : not-satisfied [no-evidence]
  route   comparator
  pattern white-managers-in-other-departments-not-similarly-situated-and-also-disciplined
  cites   stage mcdonnell-douglas.pretext
  fact @6376..6441 [supports] | Shortly after, Warren hired Beasley's replacement, who was white.
  fact @13139..13290 [cuts-against absent] | Yet Beasley never shows that he and any of these people shared the same supervisor, were subject to the same standards, or engaged in the same conduct.
  fact @13707..13837 [cuts-against] | Although he was in a similar level of management as Beasley, he had a much longer tenure at Warren-27 years as opposed to 3 years.
  fact @16933..17097 [cuts-against] | As previously noted, two other mid-level managers, both of whom were white, were disciplined in June 2015, and another white mid-level manager was eventually fired.
  rule @12244..12381 [quoted] | The plaintiff must establish "that he and the employees outside of his protected group were similarly situated in all relevant respects."
  rule @18176..18397 | Because "[t]he same analysis [applies] to claims of discrimination ... under Title VII and 42 U.S.C. § 1981," Takele v. Mayo Clinic , 576 F.3d 834, 838 (8th Cir. 2009), we use Title VII as shorthand for both claims below.
  held @17098..17178 | Without some way to tie his termination to racial animus, Beasley's claim fails.
  held @17825..18021 | Because we find that Beasley has not established intentional discrimination, either by showing that Warren treated similarly-situated employees in a disparate manner or otherwise, his claims fail.
  gloss   The prima facie stage was satisfied (replacement by a white employee); the claim failed at the pretext stage.