Johnson v. Gestamp Alabama, LLC, 946 F. Supp. 2d 1180

Plaintiff, an African-American male, was hired by Gestamp Alabama, LLC in May 2004 as a second-shift Team Leader for the UT Group and was terminated in February 2011 for alleged zero-tolerance violations (leaving the facility without permission and excessive absence).
Gestamp’s UT Group operates with first- and second-shift teams; Plaintiff previously stacked breaks with approval but later required authorization from different supervisors.
Plaintiff repeatedly complained about second-shift manpower, leadership, and training opportunities, including requests for training on cut and etch and concerns about a specific white first-shift supervisor, Kevin Childers.
Investigation by Gestamp’s HR manager Morgan and others concluded Plaintiff violated the Zero Tolerance policy, leading to his termination on March 28, 2011.
Thompson, a younger Caucasian male, replaced Plaintiff in the UT Group; later Ward and Thompson filled and transferred duties on the second shift.
Plaintiff filed suit asserting race discrimination under Title VII and § 1981, age discrimination under the ADEA, hostile work environment, retaliation, FLSA claims, and Alabama contract theories; Gestamp moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race discrimination via discharge	Plaintiff claims discharge was racially discriminatory; seeks prima facie showing with a proper comparator.	No appropriate comparator; reasons for discharge are non-discriminatory and pretext absent.	Gestamp granted summary judgment on race discharge; no valid comparator; no pretext established.
Race discrimination via training denial	Denial of training opportunities that white employees received; discriminatory impact.	No adverse action; training denied was not a material or actionable change; no valid comparator.	Gestamp granted summary judgment on training-discrimination claim.
ADEA claim (but-for causation)	Age discrimination led to termination; replacement by a younger employee shows discriminatory motive.	Reason for termination independent of age; no pretext shown.	Gestamp granted summary judgment on ADEA claim; no but-for causation shown.
Hostile work environment based on race	Racial harassment and management responses created a hostile environment.	Insufficient evidence of race-based harassment or severity; investigation and comments not racially motivated.	Gestamp granted summary judgment; no actionable hostile environment.
Retaliation under Title VII/§1981	Protected activity (complaints) caused adverse action (termination).	No causal connection; decisionmaking not shown to be retaliatory.	Gestamp granted summary judgment on retaliation claims.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination claims)
Burdine, 450 U.S. 248 (1981) ( pretext framework within McDonnell Douglas)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (pretext requires showing the proffered reason was not the true reason)
Raytheon Co. v. Hernandez, 540 U.S. 44 (2003) (applying disparate treatment standard under Title VII/§1981)
Gross v. FBL Financial Services, Inc., 557 U.S. 167 (2009) (ADEA requires but-for causation)
Holifield v. Reno, 115 F.3d 1555 (11th Cir. 1997) (similarly situated comparator standard for discrimination claims)
Lockheed Martin Corp. v. Gay, 644 F.3d 1328 (11th Cir. 2011) (convincing mosaic of circumstantial evidence approach to discrimination)
Sims v. MVM, Inc., 704 F.3d 1327 (11th Cir. 2013) (circumstantial evidence framework in age discrimination claims)
Watson v. United, 536 U.S. 101 (2002) (Morgan – hostile environment standard from federal precedent)