Davina Treadwell v. American Airlines, Inc., 447 F. App'x 676

Treadwell, a Caucasian employee at American Airlines, was fired following a day of severe delays caused by an ice storm at Memphis airport.
Horton, an African-American employee, was also fired for the same day’s on-the-job failures that contributed to the delays.
Treadwell sued in Tennessee state court for breach of contract and reverse discrimination under the Tennessee Human Rights Act; the case was removed to federal court and summary judgment was granted against her on the reverse-discrimination claim.
Treadwell produced two affidavits alleging unequal treatment of Caucasians, but the affidavits did not prove discrimination with direct evidence or establish sufficient background circumstances.
The court applied the McDonnell Douglas framework, as modified for reverse discrimination, requiring background evidence of racial discrimination against Caucasians and other factors, which Treadwell failed to prove.
The court concluded that discovery issues and lack of similarly situated employee evidence prevented a triable issue on anti-Caucasian bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether indirect evidence supports reverse discrimination	Treadwell argues the company discriminates against Caucasians as a class.	American contends no background evidence shows unusual bias against Caucasians.	No sufficient background evidence; summary judgment affirmed.
Whether background circumstances show discriminatory bias	Treadwell identifies Hymel and others as Caucasians treated unequally.	The background evidence is insufficient to show the unusual employer standard.	Background evidence lacking; no jury question.
Whether district court erred in discovery rulings	Treadwell sought post-deadline depositions to save the claim.	Defendants acted within discretion; late discovery requests were properly denied.	No abuse of discretion; affirmed.

Trans World Airlines, Inc. v. Thurston, 469 U.S. 111 (U.S. 1985) (direct and indirect evidence framework for discrimination)
White v. Baxter Healthcare Corp., 533 F.3d 381 (6th Cir. 2008) (application of McDonnell Douglas framework to reverse discrimination)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination claims)
Leadbetter v. Gilley, 385 F.3d 683 (6th Cir. 2004) (modified framework for reverse-discrimination cases)
Arendale v. City of Memphis, 519 F.3d 587 (6th Cir. 2008) (first-step background-circumstances test for reverse discrimination)
Murray v. Thistledown Racing Club, Inc., 770 F.2d 63 (6th Cir. 1985) (premise that discrimination is comparatively rare and requires background evidence)
Sutherland v. Mich. Dep’t of Treasury, 344 F.3d 603 (6th Cir. 2003) (background evidence and discrimination context in reverse-discrimination claims)
Zambetti v. Cuyahoga Comty. Coll., 314 F.3d 249 (6th Cir. 2002) (evidence of disparate treatment by the decision-maker)
Mitchell v. Toledo Hosp., 964 F.2d 577 (6th Cir. 1992) (evidence sufficiency standards in discrimination cases)