Employee Produced Sufficient Evidence On Both Single Motive And Mixed Motive Race Discrimination Claims
Todd A. White, an African-American, brought suit against his employer, Baxter Healthcare Corporation, alleging employment discrimination claims under Title VII of the Civil Rights Act of 1964. The district court granted summary judgment in favor of Baxter. On appeal, White contended that he had presented sufficient evidence for a jury to conclude that he was discriminated against on the basis of his race when Baxter: (1) failed to promote him; and (2) downgraded his performance evaluation. The 6th Circuit agreed, and reversed the grant of summary judgment, holding that: 1) White offered sufficient evidence to suggest that Baxter's purported reason for not promoting him had no basis in fact, did not motivate Baxter’s decision, or was not sufficient to explain its hiring choice; and 2) White produced sufficient evidence for a reasonable jury to find in his favor on both single motive and mixed motive race discrimination claims.
White v. Baxter Healthcare Corp.
The 6th Circuit Court of Appeals’ jurisdiction includes Michigan, Ohio, Kentucky and Tennessee.