Bart-Williams v. Exxon Mobil Corporation
1:16-cv-01338
| E.D. Va. | Sep 28, 2017Background
- Iris Bart-Williams, an African-born black female paralegal (hired 2006), worked in ExxonMobil’s Downstream Law Department; she was reassigned in 2011 from Fuels Marketing to Lubricants & Petroleum due to shifting work and later placed on a PIP and terminated March 25, 2015.
- Supervisors documented repeated performance problems (deficiencies with Excel/Word, project management failures on two box-review projects, low internal rankings) and provided coaching, a formal PIP (March–September 2014), and warnings that termination could follow if performance did not improve.
- Bart-Williams sent a complaint letter to CEO Rex Tillerson in July 2014; ExxonMobil investigated, found no policy violation, reinstated the PIP, and later terminated her for continued poor performance.
- Procedural posture: Bart-Williams sued (filed Oct. 24, 2016) alleging race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII, age discrimination and retaliation under the ADEA; ExxonMobil moved for summary judgment.
- The court focused on five issues: timeliness of claims, prima facie discrimination under McDonnell Douglas, pretext, ADEA "but-for" causation, and retaliation causation; the court granted summary judgment for ExxonMobil on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Title VII/ADEA/§1981 claims | Bart-Williams relied on incidents before EEOC/Plaintiff filing windows to support claims | Many complained-of acts occurred outside statutory filing periods (300 days for EEOC; 4 years for §1981) | Court: claims premised on conduct before 11/12/2014 (Title VII/ADEA) and before 10/24/2012 (§1981) are time-barred and dismissed |
| Prima facie discrimination (McDonnell Douglas elements) | Bart-Williams contended transfer, scrutiny, PIP, and termination show adverse action and meeting expectations | ExxonMobil: only termination is adverse; transfer was lateral and paralegal duties cross sections; documented poor performance shows she did not meet expectations | Court: Plaintiff failed to show adverse actions (other than termination), failed to show she met legitimate expectations, and failed to show circumstances giving inference of discrimination |
| Pretext for termination | Plaintiff offered isolated positive emails, alleged pressured negative reviews, and claimed fabricated evaluations | ExxonMobil produced contemporaneous supervisory evaluations, client input, ranking data, and PIP documentation as legitimate nondiscriminatory reasons | Court: Employer met burden; plaintiff failed to raise sufficient evidence that stated reasons were false or that discrimination was real reason; summary judgment for ExxonMobil |
| ADEA "but-for" causation | Plaintiff asserted an unwritten practice of forcing retirement of ≥55 employees and younger employees were transferred replacing older staff | ExxonMobil showed no replacement, many comparators were similarly aged, and no direct evidence tying age bias to termination | Court: Plaintiff failed to prove but-for age discrimination; ADEA claim dismissed |
| Retaliation (causal link) | Bart-Williams claimed her July 2014 letter to CEO was protected activity and led to termination | ExxonMobil: performance issues and PIP predated the letter; termination occurred >8 months later; no direct evidence linking the letter to termination | Court: Temporal proximity too remote and prior adverse actions negate inference; retaliation claims dismissed |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination cases)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff must show employer's reason was pretext and discriminatory intent)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (ADEA requires proof that age was the "but-for" cause)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (employer must articulate legitimate nondiscriminatory reason)
- Tex. Dep't of Cmty. Affairs v. Burdine, 450 U.S. 248 (employer production burden in McDonnell Douglas framework)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard and "genuine dispute" inquiry)
- Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369 (statute of limitations for § 1981 claims)
- O'Connor v. Consol. Coin Caterers Corp., 517 U.S. 308 (age-discrimination comparator/replacement analysis)