Goodwin v. Rite Aid Headquarters Corporation, 7:11-cv-00473

Goodwin is a licensed pharmacist who worked for Rite Aid in Tuscaloosa (Store 7039) since 1998 and became store pharmacy manager in 2002.
Plaintiff and store manager Nathan West had ongoing interpersonal conflicts regarding store operations and staffing decisions; she complained internally about West’s conduct but not about race.
Rite Aid initiated a May 2009 investigation after a technician alleged another technician dispensed and QA’d prescriptions using Goodwin’s override code; Goodwin admitted giving her code to an intern in 2008.
Goodwin was suspended without pay during the investigation and terminated on May 7, 2009; Latonya Hill, the implicated technician, was also terminated.
Goodwin filed an EEOC charge on May 13, 2009 and received a right-to-sue letter on November 9, 2010; she filed this lawsuit on February 10, 2011 asserting retaliation under 42 U.S.C. § 1983, Title VII, and the ADEA, but later abandoned most claims leaving only retaliation.
The court granted Rite Aid summary judgment, concluding Goodwin failed to prove a prima facie case of retaliation or that Rite Aid’s reasons were pretextual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Goodwin proves a prima facie retaliation case	Goodwin engaged in protected activity through complaints about management conduct.	Complaints were not protected activity tied to race or discrimination and causation is not shown.	No prima facie case; insufficient protected activity and causation.
Whether Rite Aid’s reasons for termination were legitimate and nondiscriminatory	Reasons are pretextual for discrimination based on protected activity.	Rite Aid had a legitimate, good-faith belief that Goodwin violated QA procedures by sharing her override code.	Yes, legitimate nondiscriminatory reasons established.
Whether Goodwin can show pretext to prove discrimination	Other employees’ misconduct shows pretext for harsher treatment of Goodwin.	No evidence that decisionmakers knew of comparable misconduct or that such misconduct was treated differently for Goodwin.	No pretext shown; failure to rebut legitimate reasons.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for retaliation claims)
Goldsmith v. Bagby Elevator Co., Inc., 513 F.3d 1261 (11th Cir. 2008) (prima facie retaliation elements; causation concepts)
Weeks v. Harden Mfg. Corp., 291 F.3d 1307 (11th Cir. 2002) (causation and timing relevance in retaliation)
Denney v. City of Albany, 247 F.3d 1172 (11th Cir. 2001) (employer bears burden to articulate legitimate reasons)
St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993) (pretext burden after legitimate reasons shown)