Angela Poer v. Jefferson County Commission, 100 F.4th 1325

Angela Poer, a White woman, was employed as an Administrative Services Manager for the Jefferson County Commission and reported to a Black supervisor, Trisha Wilkins.
Poer's employment was marked by documented performance issues, including poor evaluations and interpersonal conflicts, ultimately resulting in her placement on a Performance Improvement Plan (PIP).
Poer requested a lateral transfer (or reassignment), claiming the motivation was to escape Wilkins’s alleged racially discriminatory treatment, but was denied based on probationary status and performance deficiencies.
She alleged Wilkins made multiple racially insensitive remarks toward White employees and treated Black employees more favorably, but these claims were not corroborated by other witnesses or documentary evidence.
Poer was terminated near the end of her probationary period; her replacement was another White woman. She then filed claims under Title VII and 42 U.S.C. §§ 1981 and 1983, alleging race discrimination and disparate treatment.
The district court granted summary judgment for the Commission, finding insufficient evidence of race-based discrimination and that no retaliation claim had properly been pled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race Discrimination (termination and transfer denial)	Poer argued Wilkins’s racially biased comments and actions demonstrated discrimination, constituting a "convincing mosaic" of race-based animus.	Commission argued that employment decisions were based on documented performance issues, not race; no evidence tied Wilkins’s alleged bias to ultimate decision-makers.	No genuine dispute of material fact; Poer’s evidence was insufficient to show race motivated adverse actions.
Retaliation	Poer claimed her complaints and grievances triggered retaliatory adverse actions, referencing internal and EEOC filings.	Commission argued retaliation was never asserted in the complaint nor included in the EEOC charge.	Retaliation claim not properly pled; cannot be raised at summary judgment.
Hostile Work Environment	Poer cited Wilkins’s comments and alleged race-based workplace hostility as contributing to a hostile environment.	Commission argued Poer offered no corroborated, material evidence linking Wilkins’s comments to adverse actions.	District court credited the hostile work environment claim as pled, but found no actionable evidence.
Evidence of Pretext	Poer argued discrepancies and shifting rationales for transfer denial and termination revealed pretext.	Commission maintained legitimate, consistent, and documented non-discriminatory reasons for all actions taken.	No evidence of pretext; summary judgment affirmed for Commission.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes the burden-shifting framework for employment discrimination claims)
St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (explains the requirement to show the employer's reason is both false and pretext for discrimination)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard; must show genuine dispute of material fact)
Celotex Corp v. Catrett, 477 U.S. 317 (1986) (clarifies parties' respective burdens at summary judgment)
Lewis v. City of Union City, 918 F.3d 1213 (11th Cir. 2019) (McDonnell Douglas comparators; definition of similarly-situated employees)
Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (11th Cir. 2011) ("convincing mosaic" of circumstantial evidence as alternative to McDonnell Douglas)