A recent court case highlights why properly documenting employee disciplinary issues is so critical for employers.

In Craig Price II v. Valvoline, a federal appeals court upheld Valvoline’s termination of Craig Price, a Black employee who claimed race discrimination and a hostile work environment.

What was Valvoline’s saving grace in the case? Regular, policy-consistent record keeping.

Attendance policy with ‘points’

Valvoline had a clear attendance policy under which employees accrued “points” for infractions like tardiness and unexcused absences. Discipline progressed from verbal warnings to termination as an employee accumulated more points.

Price racked up points for attendance issues and received verbal and written warnings informing him that additional violations could lead to termination. After calling in sick without proper notice, Price was assessed another point — his eighth in 12 months — and fired.

Price sued, alleging that race motivated his firing and that he experienced a hostile work environment. He submitted a declaration from the plant’s only Black supervisor who reported that the plant manager had made discriminatory remarks. Per the declaration, the plant manager used the N-word repeatedly, when explaining that Black employees on the floor were using the word and asking what should be done about it. It also claimed that the plant manager said that they “needed more diversity in the workplace,” a purported implication that the plant needed fewer Black employees.

However, the 5th U.S. Circuit Court of Appeals affirmed summary judgment, citing Valvoline’s thorough paperwork trail: “Here, the evidence makes clear that Price was fired due to his repeated violations of Valvoline’s attendance policy.” Because the race-based comments at issue could not be ascribed as a contributor to Price’s firing, the court characterized them as “stray remarks.”

Takeaways for employers

This case demonstrates why carefully documenting disciplinary issues is so vital:

It creates an objective record of policy violations over time that shows legitimate, non-discriminatory reasons for discipline or termination. Without documentation, it can become a “he said, she said” situation.
It refutes claims that discipline was unfair or discriminatory by showing the employee was fully informed of expectations and consequences, and that other employees were treated in a consistent manner.
It helps protect the company from liability by evidencing good faith enforcement of known policies.

In Price’s case, Valvoline’s records made clear his firing stemmed from attendance issues. The documentation also showed Price was fully aware of the attendance rules and discipline he could face.

Documenting employee infractions takes discipline and consistency, but it’s an investment in your company’s future. Thorough records can help protect you from costly discrimination claims. More than that, they can help safeguard your reputation and build a foundation of fairness and trust within your team.