New England Biz Law Update
The 6th U.S. Circuit Court of Appeals has upheld an award of summary judgment in favor of an employer in a racial discrimination suit brought by a terminated employee who fabricated his managerial and educational experience.
“[The defendant company] hired [the plaintiff] as a production manager in its manufacturing plant. As it turns out, [the plaintiff] secured that job by fabricating his managerial and educational experience. And soon after [the plaintiff] began work, his on-the-job behavior sparked a series of complaints. Citing those performance issues, [the defendant] terminated [the plaintiff’s] employment,” Judge Whitney Downs Hermandorfer wrote for a three-judge panel.
“The district court first rejected [the plaintiff’s] claim on the basis that he lacked the required qualifications for the position. [The defendant] argues the same. But [the plaintiff] insists that [the director of operations] knew about his lack of experience and hired him anyway — an assertion [the director of operations] denies. On review, though, we can steer clear of that who-knew-what-when thicket. That’s because we agree with the district court’s alternative holding that [the plaintiff] failed to demonstrate that [the defendant’s] legitimate, nondiscriminatory reasons for firing him were pretextual. And that analysis suffices to reject Broadnax’s discrimination claims,” the court said.
“[The defendant] asserts that it terminated [the plaintiff] due to his repeated poor performance and disregard of [the defendant’s] policies. Put simply, [the plaintiff’s] lack of managerial experience showed early and often. … And [the defendant’s] summary-judgment evidence — ranging from disciplinary forms, to a documented chronology of incidents involving [the plaintiff], to deposition testimony from multiple employees — supports that the company fired [the plaintiff] because of his demonstrated poor performance. That asserted justification constitutes a legitimate, nondiscriminatory basis for [the plaintiff’s] termination,” the court added.
“At bottom, [the plaintiff] ‘has not produced evidence from which a reasonable factfinder could doubt that [he] was fired for performance-related reasons.’ … We thus affirm the district court’s grant of summary judgment to [the defendant] on [the plaintiff’s] discrimination claims,” the panel concluded.
The decision is Broadnax v. Rhombus Energy Solutions, Inc.
