Martinez v. Cracker Barrel Old Country Store, Inc.
2013 U.S. App. LEXIS 594
| 6th Cir. | 2013Background
- Ms. Martinez worked for Cracker Barrel Flint from 2000 to February 2010 as a retail manager and supervised hires and store operations.
- She acknowledged training on Cracker Barrel policies prohibiting discrimination and on reporting discriminatory conduct.
- On January 25, 2010, Martinez engaged in heated discussions with four employees about Haiti and the Bridge Card, leading to a formal complaint.
- An investigation, started February 2010, included interviews and alleged racially charged comments by Martinez, including use of the term "ghetto card."
- Cracker Barrel terminated Martinez by phone on February 12, 2010; she sued in 2010 alleging reverse discrimination under § 1981 and ELCRA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case for reverse discrimination | Martinez was qualified, suffered adverse action, and treated differently. | No valid prima facie case; Guidry not a proper comparator; Martinez failed to show discrimination. | Martinez failed to establish a prima facie case. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the burden-shifting framework for circumstantial discrimination claims)
- Zambetti v. Cuyahoga Cmty. College, 314 F.3d 249 (6th Cir. 2002) (majority-employer background-standard for majority-discrimination claims under ELCRA)
- Lind v. City of Battle Creek, 470 Mich. 230, 681 N.W.2d 334 (Mich. 2004) (ELCRA reverse-discrimination standard does not require background suspicion)
- Macy v. Hopkins Cnty. Sch. Bd. of Educ., 484 F.3d 357 (6th Cir. 2007) (similarity-prong requires substantially similar misconduct for comparators)
- Smith v. Chrysler Corp., 155 F.3d 799 (6th Cir. 1998) (employer must have reasonably informed and considered decision before adverse action)