Richardson v. Prairie Opportunity, Inc., 470 F. App'x 282

Richardson was hired in 2003 by Prairie Opportunity, Inc. as a program administrator.
Richardson filed an EEOC discrimination charge on 21 January 2009 alleging gender discrimination and pay/raise discrimination.
Marshall, Richardson's supervisor, suspended him 5 days without pay after an argument on 10 March 2009; the board later terminated him on 16 March 2009.
Richardson amended his EEOC charge to include a claim that the EEOC filing was a motivating factor in his termination.
Prairie and Marshall were granted summary judgment on the Title VII discrimination and retaliation claims, but Marshall survived on a tort claim; Richardson later dismissed the tort claim.
The district court held no genuine dispute existed about the board’s role, and this Court vacates and remands for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the board’s termination was tainted by Marshall’s animus (cat’s-paw).	Richardson contends Marshall controlled decisions and the board relied on her recommendations.	Prairie argues the board independently decided to terminate, breaking the causal link.	genuine dispute whether board's decision was tainted; remand needed.
Whether Richardson established a prima facie case and pretext for gender discrimination.	Richardson shows male status, qualification, adverse action, and more harsh treatment than female employees.	Prairie shows a legitimate nondiscriminatory reason (10 March 2009 misconduct).	summary judgment improper; facts create triable issue on discriminatory motive.
Whether Richardson established a prima facie case and pretext for retaliation.	Temporal proximity between protected activity (EEOC charge) and termination supports causation; proffered reasons questioned.	Prairie offered a legitimate reason tied to misconduct; proximity supports but not proves causation.	summary judgment improper; issues of causation/pretext to be decided by trier of fact.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the burden-shifting framework for discrimination)
Burdine v. Tex. Dept. of Cmty. Affairs, 450 U.S. 248 (U.S. 1981) (prima facie case and burden shifting in discrimination)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext evidence allows inference of discrimination)
Septimus v. Univ. of Houston, 399 F.3d 601 (5th Cir. 2005) (circumstantial evidence framework for discrimination)
Long v. Eastfield Coll., 88 F.3d 300 (5th Cir. 1996) (agency liability and cat’s-paw theory guidance)
Shager v. Upjohn Co., 913 F.2d 398 (7th Cir. 1990) (cat’s-paw/causal linkage in employment decisions)
Staub v. Proctor Hosp., 131 S. Ct. 1191 (2011) (employer liability for animus-based actions)
Evans v. City of Houston, 246 F.3d 344 (5th Cir. 2001) (temporal proximity sufficiency for causation)
Gee v. Principi, 289 F.3d 342 (5th Cir. 2002) (final-decision-maker focus in causation analysis)
Unn. unemployed benefits ALJ decision referenced, N/A (N/A) (ALJ finding used to challenge proffered reason)