Jamie McKnight v. Aimbridge Employee Service Cor, 712 F. App'x 165

Background

McKnight, an African‑American employee at the Hilton Garden Inn (managed by Aimbridge), sought transfer from kitchen (line cook) to a banquet position and completed only one day of a required three‑week banquet training.
Aimbridge required three weeks of training before employees were qualified to work in banquet roles; McKnight missed scheduled training dates and admitted little follow‑up between August and December 2014.
After complaints to the general manager and an EEOC filing, Aimbridge held an evaluation, issued a written warning/development plan, sent McKnight home early (paid), removed him from the kitchen schedule, failed to schedule him in banquet shifts, and ultimately terminated him for alleged job abandonment.
McKnight sued under 42 U.S.C. § 1981 and Title VII for racial discrimination and retaliation; the District Court granted summary judgment for Aimbridge dismissing all claims.
On appeal, McKnight argued the District Court applied incorrect standards, overlooked evidence that Aimbridge thwarted his training, and failed to address a post‑transfer scheduling discrimination claim; the Third Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether McKnight was qualified for the banquet position	McKnight argued he was qualified and Aimbridge refused to schedule him for training despite repeated requests	Aimbridge argued the hotel required completion of a three‑week training prerequisite, which McKnight did not complete	Court: McKnight was not qualified; failure to complete mandated training justified summary judgment
Whether failure to schedule after transfer supported discrimination claim	McKnight said Aimbridge granted transfer but then refused to schedule him, showing animus	Aimbridge argued plaintiff failed to show supervisors had discriminatory animus or that scheduling decisions were motivated by race	Court: Aimbridge raised the issue in its motion; McKnight failed to rebut lack of animus; claim dismissed
Whether evaluation, warning, development plan, and being sent home constitute adverse actions for retaliation	McKnight contended these actions could dissuade a reasonable worker from complaining and thus are adverse	Aimbridge argued such actions (evaluations, plans, paid early departure) are not materially adverse absent economic or term‑and‑condition changes; conceded some actions (schedule removal, termination) were adverse but offered nondiscriminatory reasons	Court: Even assuming some acts were adverse, McKnight failed to show pretext or that decisionmakers knew of protected activity; no genuine issue of material fact on causation/pretext
Standard for proving retaliation / pretext at summary judgment	McKnight argued the District Court applied a too‑stringent but‑for standard	Aimbridge relied on Fuentes/Moore framework requiring evidence that employer's reasons are false and retaliation was real reason	Court: Applied settled Third Circuit law (Fuentes/Moore); plaintiff must create fact dispute that employer’s nondiscriminatory reasons are unworthy of credence; McKnight failed to meet this burden

Key Cases Cited

Mandel v. M & Q Packaging Corp., 706 F.3d 157 (3d Cir. 2013) (elements of prima facie discrimination claim)
Makky v. Chertoff, 541 F.3d 205 (3d Cir. 2008) (prima facie framework citation)
Krouse v. Am. Sterilizer Co., 126 F.3d 494 (3d Cir. 1997) (retaliation proof requires showing employer's explanation was false and retaliation was real reason)
Fuentes v. Perskie, 32 F.3d 759 (3d Cir. 1994) (summary judgment burden to show employer's nondiscriminatory reason is unworthy of credence)
Moore v. City of Philadelphia, 461 F.3d 331 (3d Cir. 2006) (retaliation prima facie elements and causal link discussion)
Ezold v. Wolf, Block, Schorr and Solis‑Cohen, 983 F.2d 509 (3d Cir. 1992) (inferential analysis of employer proffered reasons)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for discrimination claims)