823 F. Supp. 2d 699
S.D. Ohio2011Background
- Jones is an African-American female terminated from St. Jude after 2005 employment in Columbus; Riverside account removal in Jan 2008 reduced earnings; 2008 performance rating of 2; Dr. Noble account removed in 2009; she was placed on a PIP and then terminated in Dec 2009; she filed EEOC charge June 27, 2008, and this suit followed
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discrimination: race and sex in employment decisions | Jones alleges disparate treatment based on race and sex | St. Jude denies discriminatory motive with legitimate reasons | Defendants granted summary judgment on discrimination claim |
| Retaliation for protected activity | Jones asserts actions followed EEOC charge and suit | Defendants show legitimate reasons; no causal link | Defendants granted summary judgment on retaliation claims |
| Hostile work environment | Jones alleges pervasive race/sex harassment | Insufficient severity; policy adhered; no liability | Defendants granted summary judgment on hostile environment claim |
| Wage/Equal Pay Act claim | Different pay structure and guarantees amount to unequal pay | Rates/guarantees explained; no EPA violation | Defendants granted summary judgment on EPA/Ohio wage claim |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
- Burdine, 450 U.S. 248 (1981) (burden shifting; pretext framework remains with plaintiff)
- CBOCS West, Inc. v. Humphries, 553 U.S. 442 (2008) (overlaps between Title VII and §1981; retaliation coverage)
- Asmo v. Keane, Inc., 471 F.3d 588 (2006) (employer may change rationale; pretext proof must show honest belief in nondiscriminatory reasons)
- Smith v. Chrysler Corp., 155 F.3d 799 (1998) (consideration of multiple non-discriminatory reasons; whether one is pretextual)
- Hollins v. Atlantic Co., 188 F.3d 652 (1999) (adverse action requires a material change in terms; not every action qualifies)
- Smith v. Leggett Wire Co., 220 F.3d 752 (2000) (hostile environment standards and severities; racial harassment)