Towana Carr v. Sanderson Farms, Inc.
665 F. App'x 335
| 5th Cir. | 2016Background
- Carr (white female) and Webb (African-American male) worked same shift at Sanderson Farms; Webb was in a relationship with Carr’s cousin.
- Webb threatened Carr outside work after a domestic dispute; Carr reported feeling unsafe to supervisors; employer took no action because the event occurred off-premises.
- About three weeks later Webb struck Carr twice with a pallet jack at work; Sanderson investigated and terminated both employees for gross safety violations under company policy.
- Carr filed an EEOC charge alleging racial discrimination, received a right-to-sue letter, and sued under Title VII.
- District court granted summary judgment for Sanderson; Fifth Circuit reviews and affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disparate-treatment discrimination (race/sex) | Carr contends Webb was treated more favorably given his attendance/criminal history and that race/sex motivated her firing | Sanderson says both employees committed gross safety violations and were terminated pursuant to neutral safety policy | No disparate-treatment proof: Carr failed to identify a similarly situated nonprotected comparator or evidence of discriminatory motive; summary judgment affirmed |
| Legitimate nondiscriminatory reason / pretext | Carr argues the stated safety reason was a pretext and terminations were to appease the predominantly African-American workforce | Sanderson offers investigation findings and safety policy as legitimate, nondiscriminatory reason | Held that safety concerns are legitimate; Carr presented only conclusory assertions and no substantial evidence of pretext |
| Hostile work environment (Title VII) | Carr asserts Sanderson knew of Webb’s threat and failed to remedy a hostile environment | Sanderson contends the incident was not based on protected class and therefore not Title VII harassment | Held plaintiff failed to show harassment was based on race or sex or that conditions of employment were altered by protected-class-based conduct |
| Employer failure to remediate prior to attack | Carr argues employer should have acted on her report and that inaction reveals discriminatory motives | Sanderson argues lack of notice of discrimination and that failure to follow internal procedures doesn’t itself prove bias | Court held mere failure to follow procedures or nonaction absent nexus to protected characteristic does not create triable issue of discrimination |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes prima facie framework for discrimination claims)
- Paske v. Fitzgerald, 785 F.3d 977 (discusses elements of prima facie case)
- Meritor Sav. Bank v. Vinson, 477 U.S. 57 (hostile work environment doctrine for Title VII)
- McDonald v. Santa Fe Trail Transp. Co., 427 U.S. 273 (protected-class membership under Title VII)
- Ramsey v. Henderson, 286 F.3d 264 (elements of hostile-work-environment claim)
- McCoy v. City of Shreveport, 492 F.3d 551 (safety concerns as legitimate nondiscriminatory reason)
- EEOC v. WC&M Enters., Inc., 496 F.3d 393 (severity/number of incidents relevant to hostile-work-environment analysis)