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11th Cir: No Racial Discrimination, Just Legitimate Termination

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By Betty Wang, JD on June 21, 2013 4:19 PM

The Plaintiff in a wrongful termination did not establish a prima facie face for discriminatory termination, the Eleventh Circuit ruled this week, and found no errors in the district court's decision to grant summary judgment to Plaintiff's employer.

When Nicola Hudson was terminated by Middle Flint Behavioral Healthcare, she filed a lawsuit, alleging a number of claims. One of them was that she was racially discriminated in her wrongful termination. Hudson claims that she was fired solely on the basis that she was African-American. Her complaint also alleged a racially hostile work environment, but because she failed to bring this point up again in her brief, these claims are considered abandoned.

Under Title VII, it is unlawful for employers to terminate an employee, or discriminate otherwise against any individual, because of their race. 42 U.S.C. § 2000e-2(a)(1).

Therefore, in order to establish a prima facie case for discriminatory termination under Title VII, as the plaintiff needs to show the following things: (1) she was a member of a protected class; (2) she was qualified for the job; (3) she suffered an adverse employment action, and; (4) she was replaced by someone outside the protected class. Cuddeback v. Fla. Bd. of Educ

Even if Hudson proved the existence of a prima facie case, and then Middle Flint were to provite a legitimate nondiscriminatory reason for the termination, Hudson would have been given the opportunity to then demonstrate instead that their reason was merely a pretext for discrimination.

However, none of that holds up here. Middle Flint offered evidence that their reasons for firing Hudson in the first place stemmed from the fact that she had omitted prior employment information from her job application. Also, there is evidence that further offered information showing that Middle Flint had later filled her position twice, both times with African-American females. Hudson also presented no evidence to the contrary on these matters, and the district court concluded that she had failed to established a prima facie case. She also did not show that Middle Flint's legitimate, nondiscriminatory basis for her termination was a pretext.

No genuine issues of material fact remained, and the Eleventh Circuit affirmed the district court's motion for summary judgment in favor of Middle Flint.

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