Christopher Thompson v. University of Arkansas Brd of Trustees, 52 F.4th 1039

Thompson, an African-American officer, worked at the University of Arkansas–Fort Smith Police Dept. since 2012; Raymond Ottman (white) became chief in 2015.
Thompson complained informally (Aug. 28, 2017) to Ottman’s supervisor about scheduling and alleged mistreatment, including a comment likening him to the TV character George Jefferson.
On Aug. 24, 2017, Thompson responded to a call about an intoxicated, foaming, unconscious man; body‑camera footage showed Thompson did not check vital signs, reposition the man, administer first aid, or otherwise attend to him while questioning students.
After a resident assistant complained, Ottman and supervisors reviewed the footage and concluded Thompson’s conduct warranted termination; Thompson was fired for cause on Sept. 1, 2017 for failing to provide proper first‑responder care.
Thompson sued in 2020 alleging race discrimination, hostile work environment, retaliation, and age discrimination; all claims but § 1981 claims against Ottman were dismissed. The district court granted Ottman summary judgment on the § 1981 retaliation claim; Thompson appealed only that retaliation ruling.
The Eighth Circuit affirmed, holding that no genuine dispute of material fact showed Ottman’s stated reason for termination (dangerous failure to render aid) was pretext for retaliation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether summary judgment for Ottman on Thompson's § 1981 retaliation claim was improper	Thompson: temporal proximity to his complaint, alleged inadequate investigation, purportedly inconsistent reasons, and comparators show the August 24 incident was pretextual	Ottman: termination was based on a legitimate, non‑retaliatory reason—Thompson’s failure to perform first‑responder duties shown on bodycam; no evidence linking discharge to protected complaint	Affirmed: no genuine dispute that the August 24 incident provided a legitimate, non‑retaliatory basis for dismissal and plaintiff failed to show pretext

Onyiah v. St. Cloud State Univ., 5 F.4th 926 (8th Cir. 2021) (summary judgment review standard)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment requires no genuine dispute of material fact)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden‑shifting framework for discrimination/retaliation claims)
Lake v. Yellow Transp., Inc., 596 F.3d 871 (8th Cir. 2010) (§ 1981 retaliation analyzed under McDonnell Douglas)
Gibson v. Geithner, 776 F.3d 536 (8th Cir. 2015) (ways to prove pretext: show reason false or show discriminatory motive more likely)
Fiero v. CSG Sys., Inc., 759 F.3d 874 (8th Cir. 2014) (plaintiff must point to admissible evidence creating genuine doubt about employer's motive)
Schaffhauser v. United Parcel Serv., Inc., 794 F.3d 899 (8th Cir. 2015) (employer’s deviation from disciplinary policy does not itself show pretext absent evidence linking deviation to discrimination)
McCullough v. Univ. of Ark., 559 F.3d 855 (8th Cir. 2009) (scope of employer investigation is a business judgment; investigation shortcomings alone don't prove discrimination)
Ebersole v. Novo Nordisk, Inc., 758 F.3d 917 (8th Cir. 2015) (comparators support discrimination inference only if engaged in the same conduct without distinguishing circumstances)
Smith v. Allen Health Sys., Inc., 302 F.3d 827 (8th Cir. 2002) (minor elaborations or slight changes in employer explanations are not probative of pretext)