Perlean Griffin v. Carleton Finkbeiner, 689 F.3d 584

Daugherty, a former ESD manager in Toledo, was terminated in March 2007 amid pay disparities with white managers.
He alleged race discrimination and retaliation under Title VII and Ohio law, plus a hostile-work-environment claim.
The district court granted summary judgment to the City on the discrimination claim but denied summary judgment on retaliation; it also granted in limine to exclude some other-acts evidence.
Daugherty asserted the City’s stated budgetary-reasons for termination were pretextual and that Finkbeiner’s racially charged remarks showed discriminatory atmosphere.
The district court required additional evidence beyond a prima facie case and pretext to prove discrimination, and excluded “other acts” evidence linking retaliatory terminations to Daugherty.
On appeal, the Sixth Circuit reversed, holding the proper standards allowed proceeding under single-motive or mixed-m motive analyses and remanding for reevaluation of the other-acts evidence and potential hostile-environment analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court applied the wrong standard for Title VII discrimination.	Daugherty says only prima facie, pretext suffices (no extra required).	City contends an extra reliance on discrimination-proof is required.	Incorrect; proper standard allows survival with prima facie and pretext evidence.
Whether a mixed-motive framework procedures apply to Daugherty’s claim.	Evidence of discriminatory atmosphere supports race as a motivating factor.	Discrimination must be shown as a motivating factor under proper framework.	Remanded; mixed-motive analysis applicable.
Whether the district court should admit ‘other acts’ evidence about retaliation.	Griffin and Morehead evidence is probative of retaliation against plaintiff and others.	Exclusion appropriate if not linked to the same decisionmaker; risk of mini-trials.	Not decided; remand for proper, case-specific Rule 401/403/404 analysis.
Whether hostile-work-environment claim should be analyzed.	Hostile environment claim should be considered.	Not ruled on below; no final ruling.	Remand to address hostile-work-environment claim.
Whether judgment as a matter of law against Finkbeiner was proper given Ohio-law liability.	Finkbeiner could be liable personally under Ohio law.	Federal standards may not apply to Ohio personal-liability issue.	Remand; reconsider in light of potential admitted evidence and Ohio-law standards.

Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (1990s) (prima facie case with pretext may still yield liability; not always require extra evidence)
Blair v. Henry Fittings Corp., 505 F.3d 517 (6th Cir. 2007) (summary judgment on discrimination after prima facie and pretext; Reeves framework adopted)
Geiger v. Tower Auto., 579 F.3d 614 (6th Cir. 2009) (McDonnell Douglas prima facie framework guidance)
White v. Baxter Healthcare Corp., 533 F.3d 381 (6th Cir. 2008) (mixed-motive framework; burden not onerous for evidence)
Sprint/United Mgmt. Co. v. Mendelsohn, 552 U.S. 379 (2008) (other-acts evidence; case-by-case relevance)
Hicks (St. Mary’s Honor Ctr. v. Hicks), 509 U.S. 502 (1993) (pretext standards; not the sole determinant of liability)
Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (6th Cir. 1998) (discriminatory atmosphere as circumstantial evidence)
Manzer v. Diamond Shamrock Chems. Co., 29 F.3d 1078 (6th Cir. 1994) (pretext as a factor in discrimination analysis)
Risch v. Royal Oak Police Dep’t, 581 F.3d 383 (6th Cir. 2009) (evidence of discriminatory speech by management)
Barner v. Pilkington N. Am., Inc., 399 F.3d 745 (6th Cir. 2005) (evidentiary standards for abuse of discretion)