470 F. App'x 250
5th Cir.2012Background
- Turner was hired in April 2006 as Administrative Services Support Manager in Jacobs Engineering's Baton Rouge office.
- She reported multiple instances of gender and racial discrimination and retaliation to HR in 2008, including concerns about pay and interactions with supervisor Broussard/Balkom.
- In May 2008, Turner received a performance evaluation with some unsatisfactory ratings that were later amended.
- In October 2008, workplace performance concerns were raised about staffing and collaboration between Turner’s two groups; Turner disclosed EEOC contact that month.
- Turner was terminated on or about October 27, 2008; Jacobs determined there were no suitable positions for her.
- Turner filed state-law claims in 2009; Jacobs removed and moved for summary judgment; Turner later sought leave to amend to add Title VII retaliation claims, which the district court ultimately granted summary judgment on.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Turner establish a prima facie Title VII retaliation claim? | Turner asserts protected activity and causal link to termination, including timing and cat's paw theory. | Turner failed to show decision-maker knew of protected activity or evidence of pretext; no prima facie case. | No prima facie case established; district court affirmed summary judgment. |
Key Cases Cited
- Stewart v. Miss. Transp. Comm'n, 586 F.3d 321 (5th Cir. 2009) (defines prima facie framework for retaliation summary judgment)
- Manning v. Chevron Chem. Co., 332 F.3d 874 (5th Cir. 2003) (awareness of protected activity by decision maker required)
- Staub v. Proctor Hosp., 131 S. Ct. 760 (2011) (cat's paw theory; supervisor's animus proximate cause standard)
- Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337 (5th Cir. 2007) (reasonable-inference standard for causal connection)