Michael Young v. Builders Steel Company, 2014 U.S. App. LEXIS 10643

Michael Young, an African-American employee, worked at Builders Steel for 26 years and was the sole Black employee from 2009–2011.
Young voluntarily "bid down" in 2007 from a Welder classification to Burner A (Wage Group 3), accepting a pay reduction; he claims Builders Steel promised a later pay raise that never occurred.
Union agreements defined job classifications and stated layoffs should consider (1) length of service, (2) ability, and (3) experience; seniority controlled only when ability and experience were equal.
Young filed administrative charges (MCHR/EEOC), state-court suit, and a company grievance asserting race discrimination and later alleged retaliation; he was laid off in May 2011 as part of workforce reductions.
Young was the most senior person laid off in May 2011 and the only Burner A laid off; Builders Steel retained less-senior employees with higher classifications and broader skills.
The district court granted summary judgment for Builders Steel on Young’s § 1981 discrimination and retaliation claims; Young appealed and the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race discrimination under § 1981 (prima facie inference)	Young argued similarly situated non-Black employees were treated better, company deviated from union policy, and employer explanations were false/pretextual	Builders Steel argued Wage Group 3 encompassed different jobs requiring distinct skills/certifications; layoffs were based on ability/skill, not race; no policy violation	Affirmed for defendant — Young failed to show circumstances giving rise to inference of discrimination (no similarly situated comparators; no breach of union policy; proffered pretext evidence insufficient)
Retaliation for filing complaints/charges	Young argued his protected complaints caused his May 2011 layoff; pointed to same evidence of disparate treatment and pretext	Builders Steel argued layoffs were for skill-based operational needs and lacked causal link to Young's complaints	Affirmed for defendant — Young showed protected activity and adverse action but failed to prove causal connection or pretext

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct. 1973) (burden-shifting framework for intentional discrimination)
Tusing v. Des Moines Indep. Cmty. Sch. Dist., 639 F.3d 507 (8th Cir. 2011) (standard of review for summary judgment)
Gibson v. Am. Greetings Corp., 670 F.3d 844 (8th Cir. 2012) (elements for establishing prima facie discrimination)
Lake v. Yellow Transp., Inc., 596 F.3d 871 (8th Cir. 2010) (pretext may also satisfy inference-of-discrimination element)
Chappel v. Bilco Co., 675 F.3d 1110 (8th Cir. 2012) (requirement that comparator be similarly situated in all relevant respects)
Gacek v. Owens & Minor Distrib., Inc., 666 F.3d 1142 (8th Cir. 2012) (elements of prima facie retaliation claim)