Angela Jest v. Archbold Medical Center, Inc.
561 F. App'x 887
11th Cir.2014Background
- Jest appeals district court summary judgment for Archbold on race and disability discrimination claims under Title VII, § 1981, and the ADA.
- Jest argues that a witness’s statement minimizing other employees’ misconduct was persuasive, but the court did not rely on it as controlling.
- Jest contends she established a prima facie race discrimination claim by showing adverse actions and comparators treated more favorably; she cites late clock-out discipline and others who were not disciplined.
- She asserts a convincing mosaic of circumstantial evidence of discriminatory intent, and that Archbold’s reasons for termination were pretextual.
- The district court granted summary judgment; the Eleventh Circuit applies de novo review and affirms on the record.
- On the ADA claim, Jest must show a prima facie case and show pretext for Archbold’s nondiscriminatory reasons for suspension and termination; the court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race discrimination prima facie | Jest satisfies prima facie with adverse action and comparators. | No sufficient similarly situated white employees; evidence insufficient. | No prima facie race discrimination; summary judgment affirmed. |
| Similarly situated comparators | White coworkers disciplined less; Morris was not disciplined for similar conduct. | Disparities not in all relevant aspects; not similarly situated. | No valid similarly situated comparators; race claim fails. |
| Consideration of witness statement | District court erred in weighing a witness’s claim about lack of similar misconduct. | Any error does not affect the outcome; other grounds support summary judgment. | Even if error occurred, no reversible impact; affirmed on other grounds. |
| ADA discrimination prima facie and pretext | Jest was disabled and qualified; terminated due to disability. | Proffered non-discriminatory reasons (bladder scan without order, safety, med follow-up) are valid. | Summary judgment affirmed; plaintiff failed to refute proffered reasons or show pretext. |
Key Cases Cited
- Rojas v. Florida, 285 F.3d 1339 (11th Cir. 2002) (standard for reviewing summary judgment de novo)
- Wright v. AmSouth Bancorporation, 320 F.3d 1198 (11th Cir. 2003) (summary judgment standard; weighing evidence not proper at SJ stage)
- Cuddeback v. Florida Bd. Of Educ., 381 F.3d 1230 (11th Cir. 2004) (affirming SJ on lack of pretext and similarly situated evidence)
- Holifield v. Reno, 115 F.3d 1555 (11th Cir. 1997) (elements of prima facie race discrimination circuit framework)
- Davis v. Town of Lake Park, Fla., 245 F.3d 1232 (11th Cir. 2001) (adverse action requires material change in terms of employment)
- Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (11th Cir. 2011) (same requirements for Title VII and § 1981 proof and framework)
- St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (pretext burden-shifting framework for discrimination cases)
- Joe’s Stone Crabs, Inc. v. EEOC, 296 F.3d 1265 (11th Cir. 2002) (pretext analysis requires rebuttal of nondiscriminatory reasons)