United States District Court, S.D. Mississippi, Northern Division
JIMMIE W. NATIONS, Plaintiff,
JACKSON PUBLIC SCHOOLS, ET Al., Defendants.
CARLTON W. REEVES, District Judge.
Before the Court is the defendants' motion for summary judgment. Docket No. 49. After considering the evidence, arguments, and applicable law, the motion will be granted.
I. Factual and Procedural History
From 1990 to 2012, Jimmie Nations worked as a "Supervisor III" carpenter for Jackson Public Schools. In May 2012, he was informed that his position was being eliminated due to a lack of funding and restructuring. He was terminated the next month.
Nations, who is white, filed this lawsuit alleging that JPS engaged in racial discrimination by not terminating similarly-situated non-white employees. He also alleged that his termination was retaliatory, as he had previously complained about misconduct of African-American employees and currently is a plaintiff in a "comp time" suit against JPS. Nations' claims were brought pursuant to Title VII of the Civil Rights Act of 1964.
After discovery, this motion followed.
II. Legal Standard
Summary judgment is appropriate when "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a). A party seeking to avoid summary judgment must identify admissible evidence in the record showing a fact dispute. Id. at 56(c)(1); Tran Enterprises, LLC v. DHL Exp. (USA), Inc., 627 F.3d 1004, 1010 (5th Cir. 2010). "[C]onclusory allegations, speculation, and unsubstantiated assertions are inadequate to satisfy the nonmovant's burden." Ramsey v. Henderson, 286 F.3d 264, 269 (5th Cir. 2002) (quotation marks and citation omitted).
The Court views the evidence and draws reasonable inferences in the light most favorable to the nonmovant. Maddox v. Townsend and Sons, Inc., 639 F.3d 214, 216 (5th Cir. 2011). "Although we examine the record in the light most favorable to the [non-movants], we do not do so in bits and pieces, but as a whole." Lusk v. Foxmeyer Health Corp., 129 F.3d 773, 779 (5th Cir. 1997) (affirming summary judgment in reduction in force case).
A. Race Discrimination
The familiar McDonnell Douglas burden-shifting framework applies to Title VII race discrimination claims. See McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).
To make out a prima facie case of race discrimination, the plaintiff must show that he is a member of a protected class, was qualified for the position, suffered an adverse employment action, and was replaced by someone outside his protected class. Vaughn v. Woodforest Bank, 665 F.3d 632, 636 (5th Cir. 2011). If he does so, the burden shifts to the employer to "articulate a legitimate, non-discriminatory reason for" the adverse employment action. Id. (citation omitted). If the employer satisfies that burden of production, the plaintiff must then prove that either the employer's reason is false (and therefore is a ...