Raul Escandon v. Los Angeles County
584 F. App'x 517
9th Cir.2014Background
- Escandon appeals pro se from a district court order granting summary judgment for Los Angeles County and related defendants.
- The district court considered Escandon's unauthenticated, uncorroborated documents and found no genuine material facts.
- The court applied a McDonnell Douglas burden-shifting framework to Title VII claims.
- Claims included discrimination in promotion to Senior Civil Engineer and non-selection for DPW Director, plus disparate impact and §1981/§1983 theories.
- The court held time-barred Title VII and §1983 claims, lacked jurisdiction for state tort claims, and denied discovery-related requests; judgment was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether Escandon created genuine issues of material fact | Escandon | County | No; evidence unauthenticated/uncorroborated; insufficient to raise triable issues |
| whether the promotion denial was pretextual discrimination under Title VII | Escandon relied on prima facie case | County showed legitimate, nondiscriminatory reasons (performance) | upheld; district court properly granted summary judgment for County on this claim |
| whether Escandon was not qualified for the DPW Director position undermining a prima facie case | Escandon was qualified | Escandon lacked necessary management experience | upheld; no prima facie case based on unqualified status |
| whether claims were time-barred and state tort claims lacked jurisdiction | Claims timely; state claims submitted | Claims raised after two-year period; no government claim shown | upheld; time-bar applies; no jurisdiction over state tort claims |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; absence of genuine issue of material fact)
- Blue Ridge Ins. Co. v. Stanewich, 142 F.3d 1145 (9th Cir. 1998) (de novo review of summary judgment on appeal)
- Villiarimo v. Aloha Island Air, Inc., 281 F.3d 1054 (9th Cir. 2002) (uncorroborated evidence insufficient to raise genuine issue)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for discrimination claims: prima facie, shift to employer, then pretext)
- Alameda Books, Inc. v. City of Los Angeles, 631 F.3d 1031 (9th Cir. 2011) (two-year limitations period for §1983 claims)