Ricketts v. Logics, LLC
| Decision Date | 27 September 2017 |
| Docket Number | No. 5:15-CV-293-D,5:15-CV-293-D |
| Court | U.S. District Court — Eastern District of North Carolina |
| Parties | LACHANTAL W. RICKETTS, Plaintiff, v. LOGICS, LLC, d/b/a LOGIC SOLUTIONS, Defendant. |
On February 24, 2017, defendant Logics, LLC, d/b/a Logics Solutions ("Logics") moved for summary judgment [D.E. 55] and filed a memorandum in support [D.E. 56], along with a statement of material facts [D.E. 57]. On April 17, 2017, Lachantal Ricketts ("Ricketts" or "plaintiff") responded in opposition [D.E. 62]. On April 27, 2017, Logics replied [D.E. 63]. As explained below, no rational jury could find that Logics violated Title VII of the Civil Rights Act of 1964 or discharged Ricketts in violation of North Carolina public policy. Thus, the court grants Logics's motion for summary judgment.
Logics employed Ricketts as a software trainer from April 2014 until terminating her employment on June 17, 2014. Ricketts Dep. [D.E. 57-3] 28. Ricketts's job duties included learning Logics's proprietary software and training Logics's customers to use the software. See id. at 25-27.
Ricketts contends that her work environment was racially hostile. In support, Ricketts notes that a diverse group of people regularly gathered outside Logics's building everyday. The people were visible from Logics's offices through windows. The outside group regularly included African- Americans, Caucasians, and Latinos. Id. at 48. On April 30, 2014, Ricketts was inside her office and overheard some coworkers who were outside her office refer to the people gathered outside the office as "lowlifes" and "crackheads." Id. at 47. Ricketts (an African-American woman) was offended because she believed that her coworkers were using the terms "lowlifes" and "crackheads" to describe only the African-Americans in the outside group. Id.
Later that day, Ricketts told her supervisor Adrian Thomas (an African-American man) about her coworkers' comments. Id. at 51-52. Thomas told her to ignore the comments, which were "no big deal." Id.
On May 6, 2014, Ricketts again was in her office and again overhead some coworkers who were outside her office describe a group of people gathered outside the building as "lowlifes" and "crackheads." One coworker stated that "where he was from, they would have . . . have them do like office cleaning, janitorial work, and things of that nature." Id. at 52-53. On that date, Ricketts looked out the window of her office and observed that the outside group did not include any Caucasians. Id. at 53. Ricketts again complained to Thomas about the comments, and Thomas again told her to ignore the comments. Id. at 54.
On May 7, 2014, Ricketts overheard a coworker refer to a group of people from the neighboring building as "thugs." Id. at 56-57. Ricketts stated that the group of people from the neighboring building were "minorities, mostly African-Americans." Id. Ricketts found the term "thugs" racially offensive, but admits that the comment did not interfere with her ability to perform her job. Id. at 55. Ricketts did not complain to Thomas or anyone else at Logics about her coworker using the term "thugs." See id.
Later in May 2014, Ricketts asked two Caucasian coworkers for advice about what clothesto wear to a client meeting. Id. at 55. One coworker jokingly responded, "whatever you do, just don't . . . wear any Daisy Dukes." Id. at 56. "Daisy Dukes" is a reference to short, cut-off denim short pants that a Caucasian character on the television show Dukes of Hazzard used to wear. Nonetheless, Ricketts connected the comment to other coworkers' comments she had overheard about "lowlifes," "crackheads," and "thugs" and believed that her coworker was stereotyping her due to her race. Id. Ricketts did not complain to Thomas or anyone else at Logics about the "Daisy Dukes" comment. Id. at 57.
Ricketts also cites her interaction with Caucasian coworker Elizabeth Fetherolf. According to Ricketts, Fetherolf repeatedly demanded that Ricketts submit an accounting of her time, but Ricketts claims that Thomas told Ricketts she did not need to account for her time. Id. at 80. Moreover, on one occasion, Fetherolf entered Ricketts's office and asked Ricketts to pray with her. Id. at 59. Ricketts prayed with Fetherolf for a few moments and then Fetherolf left and went back to work. Id. at 59-60. Initially, praying with Fetherolf did not offend Ricketts due to her own self-described spiritual background and because she and Fetherolf frequently discussed spirituality and religion at lunch. Nonetheless, after Fetherolf left the office, Fetherolf's prayer request offended Ricketts because Fetherolf is Caucasian. See id. at 79. Ricketts did not complain to Thomas or anyone else at Logics about Fetherolf. See Thomas Aff. [D.E. 57-1] ¶ 8.
On June 17, 2014, Thomas met with Ricketts and terminated Ricketts's employment. Ricketts claims that Thomas told her that Logics was terminating her employment because "accounts were low." Ricketts Dep. 36. Thomas testified that he never told Ricketts that Logics was terminating her employment due to a decrease in accounts. See Thomas Aff. ¶ 11. Rather, Logics terminated Ricketts's employment due to her poor performance, including failing to grasp keytechnical aspects of her job and haying "difficult communications with clients." Id. After Logics terminated Ricketts's employment, Logics had another African-American employee perform Ricketts's job duties. See id. ¶ 12.
On October 13, 2015, Ricketts sued Logics for race discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. See [D.E. 6]. The race-discrimination claim included both a claim concerning Ricketts's termination and a hostile work environment claim. Id. On July 27, 2016, the court granted Logics's motion to dismiss the complaint for failure to state a claim upon which relief can be granted, but permitted Ricketts to file an amended complaint. See [D.E. 34]. On September 8, 2016, Ricketts filed an amended complaint again alleging race discrimination and retaliation in violation of Title VII and also alleging wrongful termination in violation of North Carolina public policy embodied in N.C. Gen. Stat. § 143-422.1. See Am. Compl. [D.E. 40] ¶¶ 53-69.
In considering a motion for summary judgment, the court views the evidence in the light most favorable to the non-movant and applies well-established principles under Rule 56 of the Federal Rules of Civil Procedure. See, e.g., Fed. R. Civ. P. 56; Scott v. Harris, 550 U.S. 372, 378 (2007); Celotex Corp. v. Catrett, 477 U.S. 317, 325-26 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-55 (1986); Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 585-87 (1986). Summary judgment is appropriate "if 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); see Anderson, 477 U.S. at 247-48. The party seeking summary judgment must initially demonstrate an absence of a genuine issue of material fact or the absence of evidence to support the nonmovingparty's case. Celotex Corp., 477 U.S. at 325. Once the movant meets its burden, the nonmoving party then must affirmatively demonstrate that there exists a genuine issue of material fact for trial. See Matsushita, 475 U.S. at 587. "[T]here is no issue for trial unless there is sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party." Anderson, 477 U.S. at 249. Conjectural arguments or a "scintilla of evidence" will not suffice. See id. at 249-52; Beale v. Hardy, 769 F.2d213, 214 (4th Cir. 1985) (). "[T]here must be evidence on which the [fact finder] could reasonably find for the [nonmoving party]." Anderson, 477 U.S. at 252. In evaluating material submitted in support of or in opposition to a motion for summary judgment, the court may reject inadmissible evidence (such as hearsay). See Fed. R. Civ. P. 56(c)(4); Evans v. Techs. Applications & Serv. Co., 80 F.3d 954, 962 (4th Cir. 1996).
Title VII prohibits an employer from terminating an employee "because of such individual's race." 42 U.S.C. § 2000e-2(a)(1). A plaintiff may establish such a Title VII violation in two ways. First, a plaintiff may demonstrate through direct evidence that illegal discrimination motivated an employer's adverse employment action. Alternatively, a plaintiff may proceed under the burden-shifting framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). See generally Hill v. Lockheed Martin Logistics Mgmt., Inc., 354 F.3d 277, 284-85 (4th Cir. 2004) (en banc), abrogated in part on other grounds by Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (2013).
Direct evidence is evidence from which no inference is required. To show race discrimination by direct evidence, a plaintiff typically must show discriminatory motivation on thepart of the decisionmaker involved in the adverse employment action. See id. at 286-91. Such direct evidence would include a decisionmaker's statement that he terminated the plaintiff due to her race. See id. at 303. The decisionmaker must be either the employer's formal decisionmaker or a subordinate who was "principally responsible for," or "the actual decisionmaker behind," the allegedly discriminatory action. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 151-52 (2000); see Holley v. N.C. Dep't of Admin., 846 F. Supp. 2d 416, 427 (E.D.N.C. 2012).
Even without direct evidence of race discrimination, a plaintiff's Title VII claim can survive summary judgment if the plaintiff raises a genuine issue of material fact under the burden-shifting framework established in McDonnell Douglas. Under this analysis, a plaintiff must first establish a prima facie case of discrimination. See, e.g., ...
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