Bradley v. US Foods Inc, 4:14-cv-01772

Bradley, a former US Foods Territory Manager in Myrtle Beach, sues for Title VII race discrimination and retaliation and for state-law claims; US Foods moves for summary judgment.
Bradley’s managers included DSM Caldwell (then) and later DSM Daniel, with RSM Riggs supervising both; Bradley alleges discriminatory treatment and retaliation in the workplace.
US Foods’ employee handbook prohibited race discrimination and retaliation, and Bradley acknowledged receipt of these policies.
CentraArchy was a major account (roughly 70% of Bradley’s sales) moved in-house to the National Accounts Team in 2012–2013, reducing Bradley’s direct client interaction; SCOOP and other performance metrics (including A/R, PIPs/PAPs) governed Bradley’s performance.
Bradley resigned on November 12, 2012 before the October 2012 90‑day PIP expired; he filed an EEOC Charge on October 9, 2012; the court limits Title VII timing to events after December 14, 2011 for “discrimination” analysis; the court later finds Bradley cannot show an adverse action or causation for retaliation and grants summary judgment on multiple claims; SCWCA exclusivity bars IIED and negligent retention/supervision; public-policy wrongful termination claim not recognized in this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bradley shows a prima facie Title VII race discrimination case.	Bradley argues conduct amounted to adverse action and race-based disparity.	Bradley cannot establish an adverse action or appropriate comparator.	Bradley cannot, summary judgment granted on discrimination.
Whether Bradley shows Title VII retaliation with but-for causation.	Bradley claims protected activity (complaints to HR) caused adverse actions.	No knowledge by decision-makers of Bradley’s protected activity; actions not materially adverse.	No but-for causation; retaliation claim fails; summary judgment granted.
Whether IIED and negligent retention/supervision are barred by SCWCA exclusivity.	Exclusivity does not apply to intentional acts or hostile environment claims.	SCWCA exclusivity bars IIED and negligent retention/supervision; alter-ego and exceptions not shown.	SCWCA exclusivity bars IIED and negligent retention; grant of summary judgment on these state-law claims.
Whether Bradley’s wrongful-termination claim survives public-policy at-will analysis.	Constructive discharge/public-policy concerns support wrongful termination.	SC Supreme Court guidance declines expansion of public-policy exception; no valid exception shown.	Public-policy exception not recognized; wrongful-termination claim dismissed.

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard; credibility not weighing on jury credibility)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the burden-shifting framework in discrimination cases)
Tex. Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (U.S. 1981) (pretext framework after prima facie case)
Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S. 1998) (supervisor conduct and constructive discipline context; adverse action concepts)
DeJarnette v. Corning Inc., 133 F.3d 293 (4th Cir. 1998) (pretext and employer’s legitimate reasons; discrimination context)
Dowe v. Total Action Against Poverty in Roanoke Valley, 145 F.3d 653 (4th Cir. 1998) (causal knowledge requirement for retaliation)
Loges v. Mack Trucks, Inc., 417 S.E.2d 538 (S.C. 1992) (SCWCA exclusivity; alter ego concept limited to dominant officers)
Taghivand v. Rite Aid Corp., 768 S.E.2d 385 (S.C. 2015) (reaffirmed restraint in expanding public-policy exceptions to at-will employment)