Peoples v. T-MOBILE USA, INC.
2:22-cv-01544
D. Nev.Jun 27, 2025Background
- Stephen Peoples, an African-American former T-Mobile store manager, sued T-Mobile alleging racial discrimination, constructive discharge, and hostile work environment under Title VII, Nevada law, and 42 U.S.C. § 1981.
- Peoples first filed an EEOC complaint in 2018 after not being selected for a transfer to a higher-volume store; the EEOC dismissed the charge, and he continued working at T-Mobile.
- In 2019, employees complained about Peoples's management, and he was placed on a performance improvement plan by District Manager Scott Chassereau, whom Peoples later accused of racially charged comments.
- Peoples resigned voluntarily in December 2019 to work elsewhere, citing dissatisfaction with leadership and alleging racially hostile treatment from Chassereau; he later attempted to return to T-Mobile but was not rehired.
- Peoples filed a second charge of discrimination in March 2020, followed by this lawsuit in July 2022.
- The court considered summary judgment for T-Mobile on all claims, focusing on timeliness, adverse actions, and factual sufficiency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disparate Treatment Claim | Treated differently due to race | No adverse action or evidence; time-barred | No actionable adverse employment action or timely claim; for T-Mobile |
| Constructive Discharge | Forced to quit due to hostile conditions | No intolerable conditions at resignation | No evidence of intolerable conditions at the time of resignation |
| Hostile Work Environment | Ongoing harassment and slurs | Alleged harassment vague, outside statute of limitations | Harassment not shown within relevant 300-day window |
| § 1981 Violation | Denied equal contractual opportunities | Claims indistinguishable from others, all fail | Dismissed for same reasons as Title VII/NRS 613 claims |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (sets summary judgment standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment requires more than disputed facts; must be material)
- Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57 (1986) (hostile environment as actionable Title VII claim)
- Cornwell v. Electra Cent. Credit Union, 439 F.3d 1018 (9th Cir. 2006) (sets prima facie test for discrimination under Title VII)
- Green v. Brennan, 578 U.S. 547 (2016) (constructive discharge standard)
- Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (timeliness of hostile work environment claims)