Decision To Dock Employee's Pay For Unauthorized Sick Leave Was Not Pretext For Retaliation

Kevin Culton filed a Title VII suit against his employer, the Missouri Department of Corrections, alleging that the Department retaliated against him for confronting a supervisor about the supervisor's unwanted sexual advances toward a subordinate employee. The district court granted the Department's motion for summary judgment.  On appeal, the 8^th Circuit affirmed, holding that:  (1) for purposes of a retaliation claim based on a reassignment, Culton’s prima facie case was lacking proof of causation; (2) for purposes of a retaliation claim based on his docked pay, Culton failed to show that the department's justification for docking his pay was pretextual.

Culton v. Missouri Dep't of Corr.

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The 8th Circuit Court of Appeals’ jurisdiction includes North Dakota, South Dakota, Minnesota, Nebraska, Iowa, Missouri and Arkansas.