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Huggins v. Queen City Properties, Inc.

United States District Court, S.D. Mississippi, Northern Division

July 10, 2019




         This cause is before the court on the motion of defendants Inn City Corp., Queen City Properties, Inc. (collectively “Queen City”), Steve Anderson and Jeremy Campbell for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure. Plaintiff Judah Huggins has responded in opposition to the motion and the court, having considered the memorandum of authorities, together with attachments, submitted by the parties, concludes that the motion should be granted in part and denied in part, as set forth below.

         I. Background Facts

         Queen City owns and operates Hilton Garden Inn (HGI) in Meridian, Mississippi. Defendant Steve Anderson is the general manager of HGI, and defendant Jeremy Campbell is HGI's sales director/assistant general manager. Plaintiff Huggins, an African-American female, was employed by Queen City at the HGI in various capacities from 2014 until her termination in February 2017. Following her termination, she filed the present action against defendants alleging she was denied equal pay, subjected to a hostile work environment and ultimately terminated on account of her gender and/or race and/or in retaliation for having complained of unequal pay, all in violation of the Equal Pay Act, 29 U.S.C. § 206, and/or Title VII of the Civil Rights Act, 42 U.S.C. § 2000e et seq. and/or 42 U.S.C. § 1981. In addition to these federal claims, she asserts state law claims for negligent and intentional infliction of emotional distress, defamation and false light invasion of privacy.

         The following are the basic facts giving rise to this action, construed in the light most favorable to plaintiff. In May 2014, Anderson hired plaintiff as a desk clerk. Her pay was $10 an hour. By late 2015, she had received a number of raises and had been promoted to the position of Guest Services Manager on Duty, earning $14 an hour. In the spring of 2016, she was again promoted, to Administrative Assistant, with a pay raise to $15 an hour. At the time, Sam Davis was HGI's assistant general manager (AGM). However, in December 2015, Davis was hired as the general manager for the Meridian Hampton Inn, another Queen City hotel, and began a process of preparing to transition to his new position. Plaintiff asserts that in anticipation of Davis's departure, Anderson directed Davis to begin training her to take over his duties as AGM. When Davis did ultimately transfer to the Hampton Inn in mid-2016, she assumed his duties as AGM becoming, in effect, the de facto AGM.

         Plaintiff asserts that not only did she take over Davis's duties as AGM, but she continued to perform her duties as administrative assistant; and, in addition, at Anderson's direction, she assisted with Campbell's sales duties as Anderson was concerned that Campbell was letting a lot of things “fall through the cracks, ” as, for example, by failing to set up events he had booked for the hotel and to return phone calls and respond to emails. Given the amount of work she was performing, plaintiff presented Anderson with a letter on October 3, 2016 detailing her many job duties at HGI and requesting a pay raise to $50, 000 a year. According to plaintiff, Anderson responded that while he could not approve the $50, 000, she could have a raise; and he said that although he could not provide her a raise at that time, a raise was “in the system” and should become effective at the beginning of the year.

         Plaintiff heard nothing further from Anderson on the subject until Tuesday, January 17, 2017, when he walked into her office and gave her a letter promoting her, effective January 2, 2017, to AGM/Administrative Assistant/Sales, with an accompanying raise to $17 an hour. Less than a week later, however, on Monday, January 23, 2017, he suspended her, ostensibly for having tampered with/falsified the result of the employees' votes for the 2016 Associate of the Year Award. When confronted with the allegation that she had manipulated the election, plaintiff denied the charge; but despite her denial, Anderson immediately suspended her pending an investigation. Two weeks later, on February 6, following the investigation, she was terminated.

         Following her termination, plaintiff applied to the Mississippi Employment Security Commission (MESC) for unemployment benefits. Defendants opposed her application and reported to the the MESC that she was terminated for misconduct, that is, for tampering with the vote for Associate of the Year. While her claim for benefits was initially denied, on appeal, she was awarded benefits.

         II. Summary Judgment Standard

         Rule 56(a) provides that “[t]he court shall grant summary judgment if the movant shows that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). The movant bears the burden of demonstrating that there are no genuine issues of material fact. Once the movant meets its burden, the burden shifts to the nonmovant, “who must, by submitting or referring to evidence, set out specific facts showing that a genuine issue exists” and that summary judgment should not be granted. Norwegian Bulk Transp. A/S v. Int'l Marine Terminals P'ship, 520 F.3d 409, 412 (5th Cir. 2008). In response to a properly supported summary judgment motion, the nonmovant must “come forward with specific facts indicating a genuine issue for trial to avoid summary judgment.” Piazza's Seafood World, LLC v. Odom, 448 F.3d 744, 752 (5th Cir. 2006).

         In considering a motion for summary judgment, the court views all facts, and all reasonable inferences to be drawn from them, in the light most favorable to the nonmovant. DIRECTV, Inc. v. Budden, 420 F.3d 521, 529 (5th Cir. 2005). “If the record, viewed in the light most favorable to non-movant, could not lead a rational trier of fact to decide in non-movant's favor, summary judgment is appropriate.” Kelley v. Price-Macemon, Inc., 992 F.2d 1408, 1413 (5th Cir. 1993). But if “the factfinder could reasonably find in [the nonmovant's] favor, then summary judgment is improper.” Id. “Even if the standards of Rule 56 are met, a court has discretion to deny a motion for summary judgment if it believes that ‘the better course would be to proceed to a full trial.'” Firman v. Life Ins. Co. of N. Am., 684 F.3d 533, 538 (5th Cir. 2012) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 106 S.Ct. 2505, 2513, 91 L.Ed.2d 202 (1986)).

         III. Federal Claims:

         Discrimination: Unequal Pay

         Plaintiff has brought claims relating to her pay under the Equal Pay Act, Title VII and § 1981, each of which prohibits wage discrimination.[1] Plaintiff contends she and Campbell's positions required equal skill and effort and that she had “way more responsibilities” than Campbell and yet was paid less. The Equal Pay Act (EPA) prohibits a covered employer from discriminating “between employees on the basis of sex ... for equal work on jobs the performance of which requires equal skill, effort, and responsibility, and which are performed under similar working conditions.” 29 U.S.C. § 206(d)(1). “In short, it demands that equal wages reward equal work.” Siler-Khodr v. Univ. of Texas Health Sci. Ctr. San Antonio, 261 F.3d 542, 546 (5th Cir. 2001) (citing Corning Glass Works v. Brennan, 417 U.S. 188, 195, 94 S.Ct. 2223, 41 L.Ed.2d 1 (1974)). To establish a prima facie case of wage discrimination under the EPA, “a plaintiff must show that the employer pays different wages to men and women, the employees perform ‘equal work on jobs the performance of which requires equal skill, effort, and responsibility,' and the employees perform their jobs ‘under similar working conditions.'” Thibodeaux-Woody v. Houston Cmty. Coll., 593 Fed.Appx. 280, 283 (5th Cir. 2014) (quoting 29 U.S.C. § 206(d)(1)). Once the plaintiff establishes a prima facie case to show unequal wages for equal work, the burden shifts to the employer to prove by a preponderance of the evidence that the wage differential is justified under one of the [EPA's] four exceptions, namely, “(1) a seniority system; (2) a merit system; (3) a system which measures earnings by quantity or quality of production; or (4) any other factor other than sex.” Id.; 29 U.S.C. § 206(d)(1).

         Whereas the EPA prohibits wage discrimination based on sex, Title VII makes it unlawful for an employer to “discriminate against any individual with respect to his compensation ... because of such individual's race ... [or] sex....” 42 U.S.C. § 2000e-2(a). And, Section 1981 prohibits wage discrimination on the basis of race. Pegram v. Honeywell, Inc., 361 F.3d 272 (5th Cir. 2004). Title VII and § 1981 are parallel causes of action, with each requiring proof of the same elements to establish liability. Foley v. Univ. of Houston Sys., 355 F.3d 333 (5th Cir. 2003). To establish a prima facie case of wage discrimination under Title VII and § 1981, a plaintiff must show that she was a member of a protected class and that she was paid less than a non-member for work requiring substantially the same responsibility. Taylor v. United Parcel Serv., Inc., 554 F.3d 510, 522 (5th Cir. 2008). Pursuant to the burden-shifting framework of McDonnell Douglas, “a plaintiff's prima facie case creates an inference of ... discrimination, ” which the employer must rebut by offering a legitimate non-discriminatory reason for the pay disparity. Id. If the employer provides such a reason, the burden shifts back to the plaintiff to establish by a preponderance of the evidence that the employer's reasons are a mere pretext for discrimination. Id.; Montgomery v. Clayton Homes Inc., 65 Fed.Appx. 508 (5th Cir. 2003) (citations omitted).[2]

         To establish a prima facie case under any of these laws, the plaintiff is not required to show that her job duties were identical to those of higher paid male employees, but that they were “nearly identical” or “substantially equal” in terms of the “skill, effort and responsibility” required in the performance of the compared jobs. See Peters v. City of Shreveport, 818 F.2d 1148, 1153 (5th Cir. 1987); Reznick v. Associated Orthopedics & Sports Med., P.A., 104 Fed.Appx. 387, 390 (5th Cir. 2004) (EPA plaintiff “must show that her job requirements and ...

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