Godbolt v. Trinity Protection Services, 8:14-cv-03546

Background

Nadine Godbolt worked as a contract security officer for Trinity Protection Services from July 2011 until her termination in July 2012; Trinity staffed DOD security contracts with specific uniform, conduct, and physical requirements.
Godbolt alleges sex discrimination (Title VII) and disability discrimination (ADAAA) based on (a) being denied schedule changes/trade requests (some requests denied Sept. 23, 2011), (b) being replaced at National Center by a male when a building closed, (c) a five‑day unpaid suspension in May 2012 for rover‑log and timecard issues, and (d) termination after a July 9, 2012 incident involving a uniform violation while she says she experienced an asthma/allergic episode.
Trinity documented multiple disciplinary incidents (Sept./Oct. 2011 insubordination, May 2012 rover‑log and alleged timecard falsification, July 2012 uniform/insubordination) and issued progressive discipline including suspension, probation, and ultimately termination.
Court previously held that Title VII allegations occurring before Sept. 15, 2011 are time‑barred given Godbolt’s EEOC filing date (July 11, 2012); thus some scheduling claims (early August 2011) were dismissed as untimely.
On summary judgment, the Court found most claims within the filing window but granted Trinity summary judgment, concluding Godbolt failed to show satisfactory job performance or sufficient evidence of discriminatory motive and failed to establish that her respiratory episode amounted to a qualifying disability.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of pre‑EEOC events	Godbolt contends schedule denials and trade refusals support Title VII claims	Trinity argues many alleged acts occurred >300 days before EEOC and are time‑barred	Court: denials to pick up hours in early Aug. 2011 are time‑barred; denials that occurred or were denied by Sept. 23/26, 2011 are timely and preserved
Title VII disparate treatment (prima facie) — adverse action & comparator	Godbolt contends denial of shifts, removal from National Center, unpaid suspension, and termination show disparate treatment and differential discipline vs. males	Trinity contends some requested shift denials are non‑adverse (no tangible effect), replacement was due to seniority/collective bargaining, and male comparators were not similarly situated	Court: only removal from National Center (loss of hours/pay) and unpaid suspension are adverse; Godbolt failed to identify similarly situated male comparators and failed to show satisfactory job performance; summary judgment for Trinity
Pretext / employer motive	Godbolt argues discipline and termination were pretextual and motivated by sex bias (and collusion with supervisor)	Trinity points to documented, repeated misconduct and legitimate nondiscriminatory reasons for discipline/termination	Court: Trinity’s documented warnings and infractions are credible; Godbolt’s evidence is insufficient to show pretext or discriminatory motive; nondiscriminatory reason stands
ADAAA disability discrimination	Godbolt asserts asthma/allergic reaction at work justified ADA protection and termination was discriminatory	Trinity argues Godbolt did not show a substantial, ongoing limitation (no medical proof) and termination was for misconduct unrelated to a covered disability	Court: Godbolt failed to establish a disability under ADAAA (one‑time episode, no medical evidence of substantial limitation) and failed to show she met employer’s expectations; ADA claim dismissed

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden shifting principles)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for genuine dispute of material fact on summary judgment)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination claims)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff may prove discrimination by showing employer's reason is pretext)
Hazen Paper Co. v. Biggins, 507 U.S. 604 (causation focus in disparate treatment claims)
Bass v. E.I. DuPont de Nemours & Co., 324 F.3d 761 (employee must show meeting employer's objective performance standards)
Jacobs v. N.C. Admin. Office of the Courts, 780 F.3d 562 (ADAAA interpretation — focus on discrimination not definitional parsing)
Vannoy v. Federal Reserve Bank of Richmond, 827 F.3d 296 (employer may discipline or discharge for misconduct even if potentially related to a medical condition)