Marietta Miller-Jones v. Prince George's Cmty. Coll.
691 F. App'x 705
| 4th Cir. | 2017Background
- Miller-Jones, an African-American employee, sued Prince George’s Community College under Title VII alleging race-based failure to promote.
- The district court granted summary judgment for PGCC, finding no genuine dispute of material fact supporting discrimination.
- Miller-Jones argued the court ignored evidence, resolved factual disputes for PGCC, and impermissibly inferred non-discriminatory motives.
- PGCC argued it had a legitimate, non-discriminatory reason for its promotion decision and that summary judgment was appropriate.
- The Fourth Circuit reviewed the grant of summary judgment de novo and considered both mixed-motive and McDonnell Douglas pretext frameworks.
- The Fourth Circuit affirmed, concluding the record did not raise a genuine issue that PGCC’s proffered reason was pretext for racial discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller-Jones raised a genuine dispute that PGCC’s promotion reason was pretext for race discrimination | Miller-Jones: record and evidence create factual disputes and support inference of pretext | PGCC: articulated legitimate, non-discriminatory reason; no sufficient contrary evidence | Held for PGCC — no genuine issue of material fact that employer’s reason was pretext |
| Proper application of Title VII frameworks (mixed-motive vs. McDonnell Douglas) | Miller-Jones: evidence supports inference of discrimination under either framework | PGCC: employer’s articulated reason satisfies burden-shifting; plaintiff failed to show pretext | Court applied frameworks and found plaintiff failed to meet pretext burden |
| Whether selection committee composition undercuts discrimination claim | Miller-Jones: committee makeup does not negate discriminatory motive | PGCC: committee included members of plaintiff’s protected class, undermining inference of racial bias | Court noted that similarly composed committee makes pretext less believable and supported affirmance |
| Whether district court improperly resolved factual disputes on summary judgment | Miller-Jones: district court ignored evidence and resolved disputes for PGCC | PGCC: no disputed material facts; summary judgment proper | Court concluded district court committed no reversible error and affirmed |
Key Cases Cited
- Smith v. Gilchrist, 749 F.3d 302 (4th Cir. 2014) (standard of review on summary judgment in employment cases)
- Seremeth v. Bd. of Cty. Comm’rs, 673 F.3d 333 (4th Cir. 2012) (summary judgment appropriate when no genuine issue of material fact)
- Foster v. Univ. of Md.-E. Shore, 787 F.3d 243 (4th Cir. 2015) (mixed-motive and McDonnell Douglas frameworks under Title VII)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination claims)
- Guessous v. Fairview Prop. Invs., LLC, 828 F.3d 208 (4th Cir. 2016) (steps of the McDonnell Douglas pretext framework)
- Dennis v. Columbia Colleton Med. Ctr., Inc., 290 F.3d 639 (4th Cir. 2002) (when record conclusively reveals non-discriminatory reason, pretext fails)
- Love v. Alamance Cty. Bd. of Educ., 757 F.2d 1504 (4th Cir. 1985) (selection committee composition can undercut discrimination inference)