Arturo Martinez v. W. W. Grainger, 664 F.3d 225

Arturo Martinez, Cuban-born Hispanic, sued Grainger alleging Title VII, MHRA, and 42 U.S.C. § 1981 discrimination and breach of contract.
Martinez began at Grainger in 1994 and was promoted in 2003 to St. Paul branch manager, supervised by Jeff Timm.
Grainger classified St. Paul as a level 2 branch; Martinez was paid below the low end of the level-2 range during 2003–2005 and in 2007.
Compensation decisions depended on multiple factors (branch complexity, volume, originated sales/orders, and managerial involvement in improvement efforts).
In 2009, after employee concerns and an internal investigation led by LePage, Martinez was terminated due to the gravity of employee grievances and his leadership deficiencies.
LePage summarized recurring themes from interviews; Martinez disputed ownership of the issues; Timm concluded termination was warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie case of discrimination	Martinez (Martinez) asserts he was treated worse than non-Hispanic managers.	Grainger contends other managers with similar conduct were treated differently and criteria were non-discriminatory.	Martinez established a prima facie case; pretext failed.
Pretext for termination decision	Martinez argues Grainger's reasons are pretextual and not credible.	Grainger asserts termination based on employees' grievances and Martinez's failure to own the environment.	No showing that reasons were unworthy of credence or shifting over time.
Wage discrimination claim viability	Martinez was the only manager paid below the range for his branch level.	Pay decisions relied on multiple criteria beyond branch level and Martinez was not similarly situated to comparators.	Claim rejected; no pretext demonstrated.
Breach of contract and § 1981 claim	Continuation of employment creates unilateral contract; at-will exceptions may apply to public policy.	Handbook states at-will employment; no unilateral contract; no explicit policy violating public law.	Breach of contract claim fails; § 1981 claim fails; no enforceable contract or policy violation shown.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (burden-shifting framework for discrimination cases)
Bearden v. Int'l Paper Co., 529 F.3d 828 (8th Cir. 2008) (pretext framework for Title VII discrimination)
Putman v. Unity Health Sys., 348 F.3d 732 (8th Cir. 2003) (pretext need for discrimination finding)
Wimbley v. Cashion, 588 F.3d 959 (8th Cir. 2009) (low-threshold prima facie standard for similarly situated employees)
Clark v. Runyon, 218 F.3d 915 (8th Cir. 2000) (discipline comparisons among similarly situated employees)
Ledbetter v. Alltel Corp. Svcs., Inc., 437 F.3d 717 (8th Cir. 2006) (wage discrimination prima facie framework)
Lake v. Yellow Transp., Inc., 596 F.3d 871 (8th Cir. 2010) (pretext analysis for shifting explanations)
Smith v. Allen Health Sys., Inc., 302 F.3d 827 (8th Cir. 2002) (pretext or inconsistent facts in termination cases)
Phipps v. Clark Oil & Ref. Co., 408 N.W.2d 569 (Minn. 1987) (public policy-based wrongful discharge exceptions for at-will employees)
Martens v. Minn. Mining & Mfg. Co., 616 N.W.2d 732 (Minn. 2000) (handbook provisions too indefinite to create unilateral contract)