Boualem Habib v. Matson Navigation Co.
694 F. App'x 499
| 9th Cir. | 2017Background
- Habib appeals the district court's grant of summary judgment on his Title VII disparate treatment claim.
- The panel affirms the district court's decision and states it has jurisdiction under 28 U.S.C. § 1291.
- The court reviews de novo the grant of summary judgment and applies the standard that no genuine dispute of material fact exists.
- To survive, Habib must create a triable issue of fact on discriminatory intent, via direct/circumstantial evidence or the McDonnell Douglas framework.
- Matson contends Habib's direct evidence is absent and circumstantial evidence fails to show discriminatory motive.
- Under McDonnell Douglas, Habib fails to establish a prima facie case or show pretext; district court's ruling is upheld.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discriminatory intent present? | Habib argues discriminatory intent existed in Matson's firing decision. | Matson contends no evidence of discrimination and legitimate reasons existed. | No genuine issue; no discriminatory intent shown. |
| Direct/circumstantial evidence sufficiency? | Habib asserts evidence shows more likely discriminatory motive. | Matson's evidence fails to prove discrimination or pretext. | Evidence insufficient to prove discrimination; no triable issue. |
| McDonnell Douglas framework viability? | Habib relies on McDonnell Douglas to show pretext. | Matson offered legitimate nondiscriminatory reasons; no pretext shown. | Habib's case fails under McDonnell Douglas; reasons are believable. |
Key Cases Cited
- Vasquez v. Cty. of L.A., 349 F.3d 634 (9th Cir. 2003) (direct evidence requires inference or presumption)
- Godwin v. Hunt Wesson, Inc., 150 F.3d 1217 (9th Cir. 1998) (circumstantial proof requires more than speculation)
- Pac. Shores Props., LLC v. City of Newport Beach, 730 F.3d 1142 (9th Cir. 2013) (discriminatory reason more likely than not motivated)
- Poland v. Chertoff, 494 F.3d 1174 (9th Cir. 2007) (circumstantial evidence in discrimination cases)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard; evidence must show genuine dispute)
- Tolan v. Cotton, 134 S. Ct. 1861 (2014) (per curiam; deference to nonmovant evidence)
- Bravo v. City of Santa Maria, 665 F.3d 1076 (9th Cir. 2011) (de novo review of summary judgment standard)