Showing a non-retaliatory purpose for its actions and the absence of evidence that the employer’s explanation was “mere pretext” defeats employees’ Title VII complaint
USCA, 2nd Circuit, Docket 12-1526
A complaint filed against the Onondaga County Sheriff’s Department pursuant to Title VII of the Civil Rights Act [42 U.S.C. 2000e-3] alleged the plaintiffs had suffered retaliation as the result of their filing a complaint with EEOC.
The Department had earlier initiated an investigation of claims of racial harassment based on complaints allegedly made by prisoners at the Department’s facility that targeted the plaintiffs as engaging in discriminatory actions. Plaintiffs contend that they were then threatened with disciplinary action because of their filing “false reports” with the EEOC.
The Circuit Court of Appeals held that under the circumstances, the Department’s investigation of the complaints made by prisoners did not constitute adverse employment actions.
While the court said that threats by the Department to initiate disciplinary action charging the plaintiffs with making a false report to the EEOC established a prima facie case of unlawful retaliation, the Circuit Court ruled that the Department had shown a non-retaliatory purpose for conducting the investigation and plaintiffs presented no evidence that the Department’s explanation constituted “mere pretext.”
The Circuit Court then affirmed the district court's dismissal of plaintiffs' retaliation claims.
The decision is posted on the Internet at: http://www.ca2.uscourts.gov/decisions/isysquery/819a2023-998c-439f-ac31-d9f065e3285b/4/doc/12-1526_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/819a2023-998c-439f-ac31-d9f065e3285b/4/hilite/