James McDaniel v. National Railroad Psngr Corp.
705 F. App'x 240
| 5th Cir. | 2017Background
- Plaintiff James McDaniel, a 58-year-old white male with 25 years at Amtrak, sued after his managerial position was eliminated and he was not hired for several subsequent management jobs.
- McDaniel applied for Route Director (selected: Anella Popo, 41, African-American woman) and later for Crew Base Manager (selected: Lori Ball-Austin, African-American woman) and Onboard Services Manager (selected: Horatio Ames, African-American man).
- McDaniel alleged discrimination based on age, race, and sex under Title VII and the ADEA, and retaliation for filing internal and EEOC complaints; he also raised (but abandoned on appeal) a disparate-impact claim.
- Amtrak defended by articulating legitimate, nondiscriminatory reasons for each hire (interview performance, leadership, organization, experience); Popo was a decisionmaker for two selections and Kirk for Route Director.
- The district court granted summary judgment for Amtrak on all claims; the Fifth Circuit reviewed de novo and affirmed, finding McDaniel failed to raise genuine issues of material fact as to pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Route Director discrimination (age, race, sex) | McDaniel was better qualified and evidence (evaluations, references, tenure) shows pretext | Amtrak: legitimate reasons — Popo’s education, leadership, interview; McDaniel’s poor interview/leadership | Affirmed — Amtrak offered nondiscriminatory reasons; McDaniel did not show pretext or that he was "clearly better qualified" |
| Crew Base Manager discrimination (age, race, sex) | McDaniel claims more managerial experience and prior supervision of the role | Amtrak/Popo: Ball-Austin’s organization, multitasking, Amtrak experience supported hire | Affirmed — differences in experience not so disparate; no genuine fact issue on pretext |
| Onboard Services Manager discrimination (age, race) | McDaniel says Ames was less experienced and initially omitted from interviews suspiciously | Amtrak/Popo: Ames had relevant leadership/customer-service experience and interview strength; omission was administrative error | Affirmed — legitimate reasons unrebutted; no evidence of discriminatory motive |
| Retaliation for EEOC/internal complaints (Crew Base & Onboard Services) | McDaniel contends he was not hired in retaliation after filing complaints | Amtrak: decisionmakers unaware or had nondiscriminatory reasons; reasons not shown to be pretext | Affirmed — even assuming prima facie case, McDaniel failed to show pretext |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for burden-shifting in discrimination cases)
- Moss v. BMC Software, Inc., 610 F.3d 917 (5th Cir. 2010) (summary judgment and qualifications/pretext analysis)
- Gross v. FBL Financial Services, Inc., 557 U.S. 167 (2009) (ADEA requires but-for causation)
- Deines v. Texas Dep’t of Protective & Regulatory Servs., 164 F.3d 277 (5th Cir. 1999) (standard for "clearly better qualified")
- Laxton v. Gap, Inc., 333 F.3d 572 (5th Cir. 2003) (plaintiff must rebut each nondiscriminatory reason)