Williams v. City Richardson, 20-10417

Andre Williams, a heavy-equipment operator for the City of Richardson, applied for Solid Waste Supervisor and was interviewed by Daryl Fourte and Travis Switzer.
Williams sued the city under Title VII, the ADA, and the ADEA, and sued Fourte and Switzer under 42 U.S.C. § 1981, alleging race, age, and disability discrimination for being passed over for the promotion.
The city offered nondiscriminatory reasons for denying the promotion: Williams had worked fewer than 90 days in his current position, had not completed probation, had subpar performance, was argumentative/uncooperative for a supervisory role, and had inadequate written/oral test scores.
Williams pointed to the promoted candidate being 17 years younger and lacking a commercial driver’s license, and to alleged racist remarks by a supervisor named Jones.
The district court granted summary judgment for defendants and denied appointment of counsel; Williams appealed only the promotion-related claims and the denial of counsel.
The Fifth Circuit assumed a prima facie case but affirmed: defendants’ reasons were legitimate and Williams failed to show pretext; the denial of appointed counsel was not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether summary judgment was proper on discrimination claims for failure to promote	Williams: passed over due to race, age, and disability	City: legitimate, nondiscriminatory reasons (probation, short tenure, poor performance, test scores, attitude)	Affirmed: court assumes prima facie but finds no pretext shown; summary judgment proper
Whether the comparator hire and alleged racist remarks demonstrate pretext	Williams: promoted candidate was younger and less qualified; racist comments show bias	City: comparator had more supervisory/admin experience; Jones did not participate in hiring	Held: comparator hire was reasonable; remarks by non-decisionmaker irrelevant to this selection; not pretextual
Whether the district court abused its discretion by denying appointment of counsel	Williams: needed counsel to litigate discrimination claims	City/Court: Williams capably litigated (pleadings, briefs, evidence); law was not unusually complex	Held: denial was not an abuse of discretion
Whether other claims (different position, termination) were considered on appeal	Williams: raised additional discrimination claims	City: claims not exhausted at EEOC and/or not pleaded	Held: those claims were not exhausted or properly before the court and were not addressed on appeal

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes the burden-shifting framework for circumstantial employment-discrimination cases)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff must prove employer's stated reasons are pretext to prevail after employer rebuts prima facie case)
Tex. Dep’t of Comm. Affs. v. Burdine, 450 U.S. 248 (defendant must articulate legitimate, nondiscriminatory reasons once prima facie case is made)
McMichael v. Transocean Offshore Deepwater Drilling, Inc., 934 F.3d 447 (standard for showing a less-qualified comparator establishes pretext)
Moss v. BMC Software, Inc., 610 F.3d 917 (discusses proof needed to show a comparator is similarly situated and pretext)
Goudeau v. Nat’l Oilwell Varco, 793 F.3d 470 (application of McDonnell Douglas framework in ADEA and §1981 contexts)
Reed v. Neopost USA, Inc., 701 F.3d 434 (summary judgment standard review)
Baranowski v. Hart, 486 F.3d 112 (standard for reviewing denial of appointed counsel)
Campos v. Steves & Sons, Inc., 10 F.4th 515 (appellate principle that a district court’s judgment may be affirmed on any ground supported by the record)