Plaintiff Michelle Collins sued defendant Union Pacific Railroad Company in the United States District Court for the Western District of Missouri raising claims of race discrimination, retaliation, and hostile work environment under 42 U.S.C. § 1981. The district court granted summary judgment in favor of Union Pacific on all claims, and Collins appealed to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
Michelle Collins, a Black woman, worked for Union Pacific Railroad Company for 42 years in various positions. Collins alleged discrimination by several managers, none of whom were minorities. She claimed her manager Craig Mitchell discriminated against her in 2010 by assigning her unpleasant tasks and increasing her workload. Collins also alleged that another manager, Samantha Miller, screamed at her, prevented her from attending training, increased her workload, and changed a vacation system that would have benefited Collins.
In 2019, Collins moved to a new position as a Yard Office Coordinator. She claimed her job was made more difficult by a coworker, Rhonda VanLew, who performed poorly before turning over shifts to Collins. Collins filed an internal complaint about VanLew in 2020, while VanLew filed a separate complaint about Collins.
Collins sued Union Pacific, asserting race discrimination, retaliation, and hostile work environment claims under 42 U.S.C. § 1981. Union Pacific moved for summary judgment, arguing that Collins could not establish a prima facie case of discrimination or retaliation due to lack of adverse employment action, and that her hostile work environment claim failed because she was not subjected to severe or pervasive harassment based on race. The district court granted summary judgment on these grounds, and Collins appealed.
Legal Analysis
Discrimination and Retaliation Claims: The Eighth Circuit reversed and remanded the district court’s grant of summary judgment on Collins’s discrimination and retaliation claims. The court noted that the Supreme Court’s recent decision in Muldrow v. City of St. Louis had changed the standard for what constitutes an adverse employment action. Under Muldrow, an adverse employment action no longer needs to be “significant,” “material,” or “serious.” Instead, it is simply “a disadvantageous change to the compensation, terms, conditions, or privileges of employment.” Because the district court had relied on the now-outdated “materially significant disadvantage” standard, the Eighth Circuit remanded these claims for reconsideration in light of Muldrow.
Hostile Work Environment Claim: The Eighth Circuit affirmed the district court’s grant of summary judgment on Collins’s hostile work environment claim. The court found that Collins had failed to properly resist Union Pacific’s motion for summary judgment on the “severe or pervasive harassment” element of her claim. Collins did not provide the district court with specific facts or meaningful legal analysis to show a genuine dispute on this element. The court held that Collins could not cure these shortcomings on appeal by presenting new arguments or evidence.
The Eighth Circuit affirmed the grant of summary judgment on the hostile work environment claim but reversed and remanded the discrimination and retaliation claims for further proceedings consistent with the Muldrow decision.
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