
Plaintiff Failed To Establish Prima Facie Case
Of Wage Disparity Race Discrimination
Sheila Fields, an African-American, brought a race-discrimination suit against her former employer, Shelter Mutual Insurance, Company, pursuant to Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. Fields alleged that 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. On appeal, the 8th Circuit affirmed.
Fields v. Shelter Mutual
The 8th Circuit Court of Appeals’ jurisdiction includes North Dakota, South Dakota, Minnesota, Nebraska, Iowa, Missouri and Arkansas.