Zinnerman v. Taylor-Wharton Cryogenics, LLC, 1:17-cv-00123

Plaintiff Sheila Zinnerman sued Worthington Industries claiming discriminatory failure to hire and the district court granted summary judgment for defendant; Zinnerman timely moved under Rule 59(e) to alter or amend the judgment.
Zinnerman did not present newly discovered evidence or allege manifest factual error; her motion contended the court misapplied the legal standard on pretext and circumstantial-evidence "convincing mosaic" analysis.
She argued she did more than merely show superior qualifications or mere dislike and relied on Eleventh Circuit decisions (e.g., Thomas, Combs, Williams) to say falsity of employer’s reason alone can preclude summary judgment.
The court reviewed binding Supreme Court and Eleventh Circuit precedent explaining the plaintiff’s burden on pretext is twofold: show the employer’s proffered reason is false and show discrimination was the actual motive.
The court reiterated that federal courts do not reweigh employer business decisions and are limited to determining whether illegal discriminatory animus motivated the action.
Because the court’s summary judgment ruling conformed to controlling precedent and Zinnerman raised no new evidence or manifest legal error, her Rule 59(e) motion was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for Rule 59(e) relief	Court erred as a matter of law and should reconsider summary judgment.	Relief available only for newly discovered evidence or manifest error of law/fact; not a second bite.	Denied — no newly discovered evidence or manifest legal error.
Pretext burden at summary judgment	Zinnerman: falsity of employer’s reason (and superior qualifications) is enough to preclude summary judgment.	Worthington: plaintiff must show the proffered reason is false and discrimination was the real reason.	Denied — plaintiff must show both falsity and discriminatory motive per Supreme Court and Eleventh Circuit.
Role of circumstantial evidence / "convincing mosaic"	Zinnerman: she presented more than evidence of dislike and can create a convincing mosaic.	Worthington: evidence of dislike alone, without more linking to discriminatory motive, is insufficient.	Denied — dislike alone does not prove actionable discrimination; plaintiff failed to create a convincing mosaic.
Reliance on Thomas v. Home Depot (unpublished)	Thomas supports finding pretext where employer’s reason is disbelieved.	Thomas is inapposite; plaintiff failed to present evidence sufficient to cast doubt on the nondiscriminatory reason implicating discriminatory animus.	Denied — Thomas distinction noted; plaintiff did not cast sufficient doubt on the nondiscriminatory reason.

In re Kellogg, 197 F.3d 1116 (11th Cir.) (Rule 59(e) relief limited to newly discovered evidence or manifest error)
Michael Linet, Inc. v. Village of Wellington, 408 F.3d 757 (11th Cir. 2005) (Rule 59(e) may not be used to relitigate matters or present arguments available earlier)
Arthur v. King, 500 F.3d 1335 (11th Cir.) (same limitation on Rule 59(e))
Jacobs v. Tempur‑Pedic Int'l, Inc., 626 F.3d 1327 (11th Cir.) (reconsideration not for merits absent manifest error)
St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (plaintiff must show employer’s reason false and that discrimination was the real reason)
Chapman v. AI Transp., 229 F.3d 1012 (11th Cir.) (courts do not second-guess employer business decisions; inquiry limited to discriminatory motive)
Combs v. Plantation Patterns, 106 F.3d 1519 (11th Cir.) (discusses pretext and evidentiary standards)
Springer v. Convergys Customer Mgt. Grp., Inc., 509 F.3d 1344 (11th Cir.) (plaintiff must show nondiscriminatory reason is pretext for discrimination)