Patricia Villa v. Cavamezze Grill, LLC, 858 F.3d 896

Background

Patricia Villa, a low-level manager at CavaMezze Grill Mosaic (Mosaic), reported in Oct. 2013 that a former employee told her Mosaic’s GM, Marcelo Butron, had offered a raise in exchange for sex.
Cava’s Director of Operations, Rob Gresham, investigated by interviewing the named employees (Bonilla, Arias, and Marinero); they denied the allegations, and Gresham concluded Villa had fabricated the report.
Cava terminated Villa for making a false report; Villa later filed an EEOC charge and a Title VII retaliation suit after receiving a right-to-sue letter.
During litigation Bonilla recanted her statement to Gresham, admitting Villa’s report reflected what Bonilla had told Villa, but claimed Butron never actually made the offer.
Villa conceded the employer’s stated reason for termination was that it believed she fabricated the allegation; she argued termination was unlawful retaliation because she in fact made a truthful report and/or Cava’s investigation was unreasonable.
The district court granted summary judgment for Cava; the Fourth Circuit affirmed, holding that a good-faith factual belief that an employee fabricated a complaint is not actionable retaliation under Title VII.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether firing for allegedly fabricating a Title VII complaint violates the opposition clause	Villa: She actually made a protected complaint; firing therefore retaliatory even if employer misjudged facts	Cava: It terminated Villa because it (in good faith) believed she fabricated the complaint, so no retaliatory motive	Court: No liability where employer honestly believed employee fabricated complaint; opposition clause does not protect known fabrications
Whether subjective belief of truth is required for opposition-clause protection	Villa: Her report was true, so protected; employer’s mistake irrelevant	Cava: Opposition protection requires the employee to subjectively believe reported facts were true; employer must have perceived protected conduct	Court: Opposition clause requires the employee’s subjective belief; employer’s perception controls whether action was because of protected conduct
Whether a poor or inadequate employer investigation can establish pretext or liability	Villa: Investigation was unreasonable, creating factual dispute about pretext	Cava: Even if imperfect, investigation produced honest belief of fabrication; Villa conceded lack of pretext	Court: Evidence of inadequate investigation can show pretext, but Villa conceded Cava’s stated reason was true, so inadequate investigation alone did not create liability
Whether Supreme Court retaliation precedents (e.g., Burlington, Crawford) require broader protection against employer mistakes	Villa/Amici: Nassar/Crawford/Burlington favor broad protection to encourage reporting; employer mistakes undermine that goal	Cava: Statutory text requires but-for retaliatory motive; policy arguments cannot rewrite statute	Court: Recognized policy concerns but held precedent does not override statutory requirement of retaliatory motive; cannot expand liability beyond Congress’s text

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
University of Texas Southwestern Medical Center v. Nassar, 133 S. Ct. 2517 (retaliation requires but-for causation)
DeJarnette v. Corning Inc., 133 F.3d 293 (courts do not second-guess employer’s honestly held reason for termination)
Dowe v. Total Action Against Poverty in Roanoke Valley, 145 F.3d 653 (employer cannot act because of a factor of which it is unaware)
Glover v. South Carolina Law Enforcement Div., 170 F.3d 411 (distinguishes participation and opposition clauses)
Richey v. City of Independence, 540 F.3d 779 (opposition clause does not protect knowing fabrications)
EEOC v. Total System Services, Inc., 221 F.3d 1171 (employers may lawfully act on an honest choice between conflicting accounts)