Dennis Macklin v. FMC Transport, Inc., 815 F.3d 425

Dennis Macklin, an African American independent lease driver for FMC Transport, had a safety-point system: drivers start with 12 points and lose points for safety violations; losing all points in a year results in contract termination.
Macklin had an April 26, 2010 accident; FMC’s accident review board on May 24, 2010 found the accident preventable and deducted four points, which exhausted his annual points and led to termination.
Macklin did not appeal the board’s preventable-accident finding and later sued FMC under 42 U.S.C. § 1981 for racial discrimination after termination.
The district court granted summary judgment for FMC, concluding Macklin failed to establish a prima facie discrimination case; Macklin appealed.
The Eighth Circuit reviewed de novo, applying the McDonnell Douglas burden-shifting framework because Macklin offered no direct evidence of discrimination.
The court found Macklin failed to show he met legitimate expectations (he did not appeal the preventable finding) and failed to produce evidence creating an inference of discrimination from comparator treatment or employer animus; summary judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Macklin established a prima facie racial-discrimination claim under McDonnell Douglas	Macklin contends his accident was not preventable and that FMC treated similarly situated white drivers more favorably (different point deductions, failure to record some accidents, rehiring others) and employees displayed racial animus	FMC argues it followed its safety policies, Macklin didn’t appeal the preventable finding, and comparators aren’t shown to be similarly situated; no evidence linking coworker animus to decisionmakers	Macklin failed to establish a prima facie case because he did not show he met legitimate expectations or present evidence creating an inference of discrimination; summary judgment affirmed

Young v. Builders Steel Co., 754 F.3d 573 (8th Cir. 2014) (summary-judgment and McDonnell Douglas framework guidance)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct.) (burden-shifting framework for discrimination claims)
Humphries v. Pulaski Cty. Special Sch. Dist., 580 F.3d 688 (8th Cir. 2009) (direct evidence vs. McDonnell Douglas analysis)
Gibson v. Am. Greetings Corp., 670 F.3d 844 (8th Cir. 2012) (elements of prima facie discrimination case)
Davis v. Jefferson Hosp. Ass’n, 685 F.3d 675 (8th Cir. 2012) (prima facie presumption discussion)
Chappell v. Bilco Co., 675 F.3d 1110 (8th Cir. 2012) (similarly situated comparator analysis)
Lake v. Yellow Transp., Inc., 596 F.3d 871 (8th Cir. 2010) (inference of discrimination where employer fails to follow its own policies)
Griffith v. City of Des Moines, 387 F.3d 733 (8th Cir. 2004) (attribution of coworker bias to employer decisionmakers)
Mann v. Yarnell, 497 F.3d 822 (8th Cir. 2007) (summary-judgment evidence standard)