Beasley v. Warren Unilube, Inc.

933 F.3d 932 (2019) United States Court of Appeals for the Eighth Circuit 2019-08-09

civil; Title VII and Section 1981 discriminatory discharge; summary judgment for employer affirmed by CA8 (result: claimant-lost)

Facts

  1. 1 Persons protected by equal contractual rights satisfied conceded
    He plainly meets the first and third requirements: he is a member of a protected group and was fired.
  2. 2 Plaintiff has rights in an existing or proposed contract satisfied conceded
    Beasley started working as the Quality Assurance Manager at Warren in October 2012.
  3. 4 Judicial intentional-race-discrimination requirement not no-evidence
    Shortly after, Warren hired Beasley's replacement, who was white.
  4. 4 Judicial intentional-race-discrimination requirement not no-evidence
    The plaintiff must establish "that he and the employees outside of his protected group were similarly situated in all relevant respects."
  5. 4 Judicial intentional-race-discrimination requirement not no-evidence
    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.
  6. 4 Judicial intentional-race-discrimination requirement not no-evidence
    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.
  7. 4 Judicial intentional-race-discrimination requirement not no-evidence
    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.
  8. 4 Judicial intentional-race-discrimination requirement not no-evidence
    Without some way to tie his termination to racial animus, Beasley's claim fails.
  9. 4 Judicial intentional-race-discrimination requirement not no-evidence
    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.
  10. 4 Judicial intentional-race-discrimination requirement not no-evidence
    Because "[t]he same analysis [applies] to claims of discrimination ... under Title VII and 42 U.S.C. ยง 1981," Takele v. Mayo Clinic , 576 F.3d 834, 838 (8th Cir. 2009), we use Title VII as shorthand for both claims below.
  11. 6 Nongovernmental impairment satisfied conceded
    Warren produces motor oil and other automotive lubricants.