Joseph L. Cooler v. Layne Christensen Company, 710 F. App'x 842

Joseph Cooler, an African American employee, worked as a driller helper and in a warehouse for Layne Christensen Company beginning June 2013 and alleged repeated racially hostile treatment by supervisors and coworkers.
Reported incidents include being told to "cool off" in a hot metal toolshed (resulting in hospitalization for dehydration), being called "boy" and "you people," repeated use of the N-word by two supervisors in conversations with him, confederate-flag decals on coworkers' cars, gay slurs about his braided hair, and being told he was unwelcome in the break room.
Cooler complained internally about some conduct and later filed an EEOC charge after Layne fired him following an alleged training absence at a company-paid session in Baton Rouge in May 2014.
Layne defended the termination as discipline for missing training time; supervisor Darryl Ross (an African American manager) made the termination decision and documented perceived misconduct.
The district court granted summary judgment to Layne on all claims; Cooler appealed. The Eleventh Circuit affirmed summary judgment on retaliation and race-discrimination claims but reversed and remanded as to the hostile work environment claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retaliation under § 1981	Cooler: termination was retaliation for his EEOC charge; Layne seized first opportunity to retaliate (missed training).	Layne: temporal gap between protected activity and firing breaks causal link; continuous employment gives employer ongoing opportunity to retaliate so "first opportunity" theory fails here.	Affirmed for Layne — Cooler failed to show causation given delay and no other evidence of retaliatory motive.
Race discrimination (disparate treatment)	Cooler: circumstantial evidence (epithets, treatment, assignments) creates a "convincing mosaic" of discrimination.	Layne: decisionmaker (Ross) did not engage in the alleged discriminatory acts; Cooler lacks similarly situated comparator and stronger proof of discriminatory motive.	Affirmed for Layne — evidence insufficient to infer intentional discrimination by the decisionmaker.
Hostile work environment (Title VII and § 1981)	Cooler: frequent racial epithets, demeaning assignments, exclusion from break room, and safety/health incident create severe and pervasive harassment.	Layne: some uses of words may be contextual/isolated; prior incidents insufficiently severe or pervasive.	Reversed and remanded — a reasonable jury could find harassment severe or pervasive under the totality of circumstances.

Peppers v. Cobb Cty., 835 F.3d 1289 (11th Cir. 2016) (summary-judgment standard and factual-viewing principles)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (standard for when a reasonable jury could return a verdict for the nonmoving party)
Goldsmith v. Bagby Elevator Co., 513 F.3d 1261 (11th Cir. 2008) (elements of § 1981 retaliation claim)
Thomas v. Cooper Lighting, Inc., 506 F.3d 1361 (11th Cir. 2007) (temporal gap requires additional evidence to prove causation for retaliation)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for circumstantial employment discrimination)
Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (11th Cir. 2011) ("convincing mosaic" approach to circumstantial evidence of discrimination)
Adams v. Austal, USA, LLC, 754 F.3d 1240 (11th Cir. 2014) (hostile-work-environment analysis and context for racial slurs)
Jones v. UPS Ground Freight, 683 F.3d 1283 (11th Cir. 2012) (factors to evaluate severity and pervasiveness and totality-of-circumstances test)
Butler v. Ala. Dep’t of Transp., 536 F.3d 1209 (11th Cir. 2008) (single use of racial epithet, in isolation, may be insufficient for hostile-work-environment)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S. 1993) (Title VII hostile-work-environment standard)