Jones v. Gulf Coast Restaurant, 8 F.4th 363

Jones, a Black employee, worked at Half Shell (promoted to Assistant Kitchen Manager, Biloxi) under GM Chad Henson; he sought a Kitchen Manager promotion in 2018.
Management told Jones front-of-house experience was preferred; he never received that training. In July 2018 he trained in Covington but was reprimanded for kitchen mistakes (burnt almonds; deviating from gumbo recipe) and received a stern email.
John Wiggins, a white trainer with less experience and no front-of-house background, was promoted to Kitchen Manager; Jones reacted, left training early, and complained to Henson about discrimination but did not escalate internally.
In October 2018 Jones added crab meat to a cooled seafood pot pie, later told Henson another employee (Morgan) cooked it; Henson reviewed video, concluded Jones lied and mishandled the dish, and—after consulting area manager Graham—terminated Jones on October 10, 2018; Morgan (non-Black) was promoted to Assistant Kitchen Manager.
Jones filed an EEOC charge (Dec 2018), sued under § 1981 and Title VII (Oct 2019) alleging racial discrimination and retaliation, and sued Henson under Mississippi law for tortious interference; the district court granted summary judgment to defendants and Jones appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Half Shell's stated reasons (lying about who cooked the pot pie; failing to follow recipe) were pretext for racial discrimination/retaliation under Title VII/§ 1981	Jones says he did not lie (he only "finished" the dish by adding crab) and he followed the recipe; termination was actually discriminatory/retaliatory after his complaint about Wiggins's promotion	Defendants contend they honestly relied on video and prior performance issues (Covington reprimand) to conclude Jones lied and violated recipe policy; reasons are nondiscriminatory	Court: Granted summary judgment for defendants—Jones failed to produce substantial evidence that the proffered reasons were false or pretextual
Whether Henson tortiously interfered with Jones’s employment under Mississippi law (requires malice/bad faith)	Jones argues Henson acted with malice/bad faith in causing his termination	Henson says he acted within his managerial role and in good faith; no malice	Court: Judgment for Henson—Jones failed to show malice or bad faith, so tortious-interference claim fails

Brown v. Wal-Mart Stores E., L.P., 969 F.3d 571 (5th Cir. 2020) (McDonnell Douglas burden-shifting and pretext analysis)
Harville v. City of Houston, 945 F.3d 870 (5th Cir. 2019) (Title VII/§ 1981 same-proof rule and framework)
Watkins v. Tregre, 997 F.3d 275 (5th Cir. 2021) (pretext as employer explanation being false)
Laxton v. Gap Inc., 333 F.3d 572 (5th Cir. 2003) (methods for proving pretext)
Wallace v. Methodist Hosp. Sys., 271 F.3d 212 (5th Cir. 2001) (plaintiff must rebut each nondiscriminatory reason with substantial evidence)
Moore v. Eli Lilly & Co., 990 F.2d 812 (5th Cir. 1993) (mere refutation of employer's reasons is insufficient)
Shackelford v. Deloitte & Touche, LLP, 190 F.3d 398 (5th Cir. 1999) (subjective disagreement about performance does not alone establish pretext)
Price v. Fed. Exp. Corp., 283 F.3d 715 (5th Cir. 2002) (genuine but subjective belief of discrimination insufficient absent supporting evidence)
In re La. Crawfish Producers, 852 F.3d 456 (5th Cir. 2017) (summary judgment standard and inference drawing)
Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337 (5th Cir. 2007) (nonmoving party cannot rely on conclusory allegations to avoid summary judgment)
McClinton v. Delta Pride Catfish, Inc., 792 So. 2d 968 (Miss. 2001) (elements of tortious interference with employment)
Shaw v. Burchfield, 481 So. 2d 247 (Miss. 1985) (supervisors acting within scope and in good faith not liable for tortious interference)