Brandt v. Fitzpatrick, 957 F.3d 67

Background

Christopher Brandt, an African American corrections officer, worked for the Maine Department of Corrections (MDOC) from late 2012–Jan 2014 and repeatedly applied (unsuccessfully) for probation-side positions.
In April 2013 Brandt sent a letter to Commissioner Ponte complaining about a "good ole boy network" and perceived lack of diversity in the Probation Division; he subsequently filed a Maine Human Rights Commission (MHRC) charge in November 2013.
Brandt resigned effective Jan 8, 2014 after accepting a federal corrections job; that federal offer was later rescinded due to a hiring freeze, so Brandt sought rehiring by MDOC.
MDOC officials (Warden Landry and deputy LaPlante) investigated Brandt's explanation that the federal offer fell through because of a hiring freeze; LaPlante concluded (based on contacts) Brandt had lied and recommended non-rehire; Landry relied on that and denied reinstatement.
It later appeared the federal hiring freeze had in fact prevented Brandt's hire; Brandt sued MDOC alleging Title VII race discrimination (mixed-motive/stereotyping and cat's-paw theories) and retaliation for his complaints.
The district court granted summary judgment for MDOC; the First Circuit affirmed, holding Brandt failed to create a triable issue of racial animus or pretext and failed to show but-for causation for retaliation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race discrimination — stereotyping/mixed-motive	Landry relied on racial stereotypes (e.g., branded Brandt a "black and white" thinker; trusted LaPlante over Brandt) so race was a motivating factor.	Landry's interview conduct and reliance on LaPlante reflected nondiscriminatory judgments about qualifications and credibility, not racial animus.	No genuine issue: record shows nondiscriminatory reasons (qualification concerns, perceived dishonesty); stereotyping inference unsupported. Summary judgment affirmed.
Cat's paw (derivative liability for LaPlante's alleged bias)	LaPlante manufactured or manipulated false information about the federal hiring freeze to block Brandt; Landry merely acted as conduit.	LaPlante genuinely believed Berlin was hiring and truthfully relayed what HR told him; no evidence LaPlante acted from racial animus or that his investigation was a sham.	Denied: Brandt failed to show LaPlante harbored racial animus or that his report was a sham; cat's-paw theory does not save the claim.
Retaliation for complaint to Ponte/MHRC	Landry (or MDOC) refused to rehire Brandt in retaliation for his complaints to Ponte and his MHRC charge.	Landry/LaPlante lacked knowledge of the MHRC charge at decision time; nondiscriminatory reasons (concern Brandt would leave; perceived untruthfulness) explain refusal.	Denied: no but-for causation or evidence of pretext; temporal gap and absence of decisionmaker knowledge defeat retaliation claim.

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination claims)
Price Waterhouse v. Hopkins, 490 U.S. 228 (1989) (recognizes mixed-motive liability where illegitimate considerations are a motivating factor)
Desert Palace, Inc. v. Costa, 539 U.S. 90 (2003) (circumstantial evidence can sustain mixed-motive Title VII claims)
Thomas v. Eastman Kodak Co., 183 F.3d 38 (1st Cir. 1999) (Title VII bars evaluations based on racial stereotyping even without conscious intent)
Staub v. Proctor Hosp., 562 U.S. 411 (2011) (articulates standards for indirect liability when biased subordinate influences adverse action)
Ameen v. Amphenol Printed Circuits, Inc., 777 F.3d 63 (1st Cir. 2015) (discusses cat's-paw liability in employment contexts)
Mesnick v. Gen. Elec. Co., 950 F.2d 816 (1st Cir. 1991) (courts should not second-guess employer business judgments absent discriminatory animus)
Kouvchinov v. Parametric Tech. Corp., 537 F.3d 62 (1st Cir. 2008) (plaintiff must show deceit or sham to prove pretext beyond mere inaccuracy)
Adamson v. Walgreens Co., 750 F.3d 73 (1st Cir. 2014) (employer's failure to hear employee's explanation does not alone show pretext)
Univ. of Texas Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (2013) (retaliation claims require but-for causation)