Chapter 7 Trustee v. Gate Gourmet, Inc.
2012 U.S. App. LEXIS 11793
| 11th Cir. | 2012Background
- Stacey Williams, a white pregnant employee, began working as a Gate Gourmet customer service representative at ATL in March 2008.
- Her duties included driving a catering truck and moving heavy carts; she reported pregnancy-related difficulty with truck duties in August 2008.
- On August 11, 2008, Baxter and others discussed her pregnancy and potential light-duty options; a note later restricting her duties was provided August 14, 2008.
- Williams was told no light-duty positions were available and was terminated (or treated as terminated) after presenting restrictions; Gate Gourmet later claimed she was never officially terminated.
- Gate Gourmet acknowledged a light-duty position (silverware wrapper) was available on August 18, 2008, and that the policy allowed offering light-duty work for medical conditions.
- EEOC charge and union grievance followed; Gate Gourmet offered back pay and reinstatement contingent on dropping the EEOC charge, which Williams refused; state-law negligence claims were asserted as derivative claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pregnancy discrimination via indirect evidence | Williams shows circumstantial intent to discriminate based on pregnancy. | No comparator or legitimate nondiscriminatory reason shown to explain termination. | Pregnancy discrimination claim survives summary judgment on circumstantial evidence. |
| Race discrimination via indirect evidence | Williams asserts pretext and disparate treatment based on race using noncomparator evidence. | Proffered reasons could be legitimate and pretext not proven; disparate treatment not shown. | District court erred in granting summary judgment on race discrimination; claim should be evaluated for pretext and evidence. |
| Retaliation claim viability | Denying light-duty position after EEOC charge constitutes retaliation; sequence shows causal connection. | Evidence insufficient to tie denial to protected activity; offer to settle not retaliatory. | Summary judgment on retaliation reversed; triable issue exists regarding causal connection. |
| State-law claims derived from federal claims | Negligence-based claims hinge on discrimination/retaliation and should proceed. | Claims derivative and should fail where federal claims fail. | Affirmed in part and reversed/remanded in part; state-law claims remanded consistent with federal claim outcomes. |
| Impact of non-termination evidence on retaliation | Inconsistencies show Williams was not officially terminated, supporting adverse action analysis. | Statements of non-termination undermine adverse-action link. | Evidence creates material issue; cannot grant summary judgment on retaliation. |
Key Cases Cited
- Armstrong v. Flowers Hosp., Inc., 33 F.3d 1308 (11th Cir. 1994) (uses sex/pregnancy framework for discrimination claims)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for indirect discrimination evidence)
- Burdine, 450 U.S. 248 (U.S. 1981) (pretext framework after prima facie case)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (ultimate burden remains with plaintiff; pretext analysis)
- Smith v. Lockheed-Martin, 644 F.3d 1321 (11th Cir. 2011) (flexible approaches to prima facie and circumstantial evidence)
- Rioux v. City of Atlanta, 520 F.3d 1269 (11th Cir. 2008) (circumstantial evidence can establish discrimination without a comparator)
- Goldsmith v. Bagby Elevator Co., 513 F.3d 1261 (11th Cir. 2008) (causal link; protected activity can be linked to adverse action)
- Burlington Northern Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (materially adverse action in retaliation standard)