Crawford v. Karcher North America, Inc., 5:18-cv-05018

Background

Plaintiff Charlene Crawford was the warehouse manager at Karcher North America’s Fayetteville, AR distribution center, reporting to Ed Taylor (Director of Operations); she supervised ~59 employees.
From 2013 onward Crawford complained to HR about Taylor’s management style; in April 2016 an exchange after a meeting led to a coaching session and Crawford requested an investigation into allegations she had been a “bully.”
In early 2017 Crawford was the subject of two management-related incidents: (1) failure to timely report damage to a vendor trailer and (2) delayed reporting/handling of an employee injury; she received a verbal warning and HR recommended termination.
Karcher had been pursuing a planned reorganization to reduce costs and eliminate the warehouse manager position; management (including Taylor, HR, and senior executives) agreed to eliminate the role and terminated Crawford on March 28, 2017, citing organizational changes.
Crawford sued for gender discrimination and retaliation under Title VII and the Arkansas Civil Rights Act, arguing unequal treatment compared to Taylor and retaliation for reporting discrimination; Karcher moved for summary judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crawford established a prima facie gender-discrimination claim (including being discharged under circumstances giving rise to inference of discrimination)	Crawford argues she was treated less favorably than male manager Ed Taylor and that gender played a role in her termination	Karcher contends Crawford cannot show she was treated differently than a similarly situated male and that elimination of the position was a legitimate business decision	Court: Crawford failed to show she and Taylor were similarly situated; prima facie case not established
Whether Karcher offered a legitimate nondiscriminatory reason and whether that reason was pretextual	Crawford contends Karcher’s stated reasons lack factual basis and are pretext for discrimination	Karcher asserted legitimate reasons: cost-driven reorganization and concerns about Crawford’s management of two incidents; employer honestly believed those reasons	Court: Karcher gave legitimate nondiscriminatory reasons; evidence does not show pretext or discriminatory motive
Whether Crawford can prove retaliation (protected activity and "but-for" causation)	Crawford says she engaged in protected activity by complaining about Taylor and seeking investigation, and was terminated in retaliation	Karcher argues Crawford’s complaints did not allege sex discrimination specifically and thus were not protected; termination was for business/disciplinary reasons	Court: Crawford did not engage in protected activity as required and cannot show but-for causation; retaliation claim fails
Appropriateness of summary judgment	Crawford argues factual disputes defeat summary judgment	Karcher argues no genuine dispute as to material facts supporting its lawful reasons for termination	Court: Summary judgment granted for Karcher; all claims dismissed with prejudice

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for employment discrimination)
McGinnis v. Union Pac. R.R., 496 F.3d 868 (discusses direct evidence standard in discrimination cases)
Radabaugh v. Zip Feed Mills, Inc., 997 F.2d 444 (definition of direct evidence of discriminatory animus)
Wierman v. Casey’s Gen. Stores, 638 F.3d 984 (elements of prima facie case under McDonnell Douglas)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (plaintiff must show employer’s proffered reason is pretext and that discrimination was the real reason)
Evers v. Alliant Techsystems, Inc., 241 F.3d 948 (decline in revenue and reduction-in-force is a legitimate business reason for termination)