Bratton v. City of Bessemer, 2:10-cv-01854

Bratton, a Caucasian, was hired as Water Utilities Serviceman by the City of Bessemer on Sept 3/4, 2009 without the Mayor's direct involvement; white supervisors interviewed him and the Mayor signed off on hiring.
Following a hostile encounter with African-American coworkers in Bratton’s first month, several black employees verbally attacked him and others at a meeting; some made racially charged remarks.
During a January 2010 cold snap, eleven water service employees claimed overtime was underpaid based on time clocks; the City reviewed time sheets and issued adjusted overtime payments after meetings.
Bratton’s overtime hours were found to be overstated on his initial claims, with substantial adjustments made during investigations; he acknowledged some miscalculations due to first-time on-call duties.
In March 2010, Bratton was terminated while still in his new-hire probationary period, reportedly for miscalculation of overtime, with the Mayor unaware of Bratton’s race at the time of termination.
The City’s memorandum and actions singled Bratton out among others who miscalculated overtime; the record shows another African-American employee, Lewis, who was not terminated, though in a different probationary context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
FLSA overtime entitlement	Bratton seeks unpaid overtime hours overtime.	Overtime miscalculation did not prove failure to pay for all due hours; evidence contested.	FLSA claim denied as to City; triable issue remaining on disputed hours
FLSA retaliation	Termination followed overtime complaint; retaliation plausible.	Non-retaliatory reason: probationary status and miscalculation; evidence of pretext lacking.	FLSA retaliation claim granted in favor of City; Bratton's claim rejected
Race discrimination by City under 42 U.S.C. §1981	Bratton terminated due to race; mayor aware of race; comparator treatment alleged.	No proof mayor knew Bratton’s race; no valid comparator; reasons non-discriminatory.	City summary judgment on race discrimination claim granted
Race discrimination by Mayor May individually	May individually discriminated based on race.	No evidence May knew Bratton’s race; qualified immunity not reached; no direct evidence of discriminatory intent.	Mayor May summary judgment granted
Ala. Code § 11-43A-45 (municipal discrimination prohibition) applicability	Discrimination in municipal employment prohibited; City liable.	Form of government and abandonment of claim; statute inapplicable to City form.	Claims under Ala. Code § 11-43A-45 granted summary judgment for City

Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden-shifting framework for summary judgment)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (evidence standard for genuine disputes of material fact)
Reich v. Dep’t of Conservation and Natural Resources, 28 F.3d 1076 (11th Cir. 1994) (plaintiff must show overtime exists and employer knew or had reason to know)
Holifield v. Reno, 115 F.3d 1555 (11th Cir. 1997) (similarly situated comparator analysis in discrimination cases)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (summary judgment standard; impermissible to rely on speculation)