Plaintiffs Gerald Kettler, Dennis Boatwright, and Catherine Politte sued defendant Metropolitan St. Louis Sewer District (MSD) in the United States District Court for the Eastern District of Missouri raising claims of race and gender discrimination under 42 U.S.C. § 1981, Title VII, and the Missouri Human Rights Act. Before the court is Defendant MSD’s motion for summary judgment.
Statement of Undisputed Facts
MSD is a municipal corporation and political subdivision of Missouri with policies prohibiting discrimination and harassment. In 2020, Kettler and Boatwright were terminated for claiming hours on timecards that could not be supported by evidence. Politte, an Assistant Director of Operations, was terminated in 2022 after an investigation found she had violated MSD’s policies against discrimination, retaliation, and disclosure of confidential information during a hiring process.
Evidentiary Disputes: The court addressed MSD’s motion to strike portions of Politte’s declaration submitted in support of Kettler and Boatwright’s response to summary judgment. The court disregarded certain paragraphs containing statements lacking personal knowledge, legal conclusions, and inadmissible hearsay.
Legal Analysis
Section 1981 Claims: The court found that Plaintiffs’ § 1981 claims must be brought under § 1983 because MSD is a municipal corporation. The court liberally construed the complaint as including § 1983 claims.
Municipal Liability under § 1983: The court determined that Plaintiffs failed to establish municipal liability under § 1983 because they did not show that the alleged violations resulted from an official policy or unofficial custom of MSD.
Prima Facie Case and Pretext: The court focused on Politte’s remaining Title VII and MHRA claims. Assuming Politte established a prima facie case of discrimination, the court found that she failed to show MSD’s legitimate, non-discriminatory reason for her termination was pretext. Politte did not provide sufficient evidence to dispute MSD’s findings that she violated company policies, nor did she present similarly situated comparators who were treated more favorably.
The court granted MSD’s motions for summary judgment and dismissed all of Plaintiffs’ claims with prejudice.
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