Daniel Snyder sued Arconic Corporation and Arconic Davenport, LLC in the United States District Court for the Southern District of Iowa, raising claims of religious discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Iowa Civil Rights Act. The district court granted summary judgment in favor of Arconic, and Snyder appealed to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
Daniel Snyder, a former employee of Arconic Davenport LLC, was fired after posting a comment on the company’s intranet site about the rainbow symbol. Snyder believed he was responding to an anonymous survey, but his comment was instead posted publicly on a message board visible to all employees. The comment read: “It’s a abomination to God. Rainbow is not meant to be displayed as a sign for sexual gender.”
Arconic suspended Snyder for making an offensive comment that violated the company’s Diversity Policy and antiharassment policy. After an investigation, Arconic terminated Snyder’s employment, citing the post and his history of disciplinary issues. Snyder then sued Arconic for religious discrimination and retaliation.
Both parties filed cross-motions for summary judgment. The district court denied Snyder’s motion and granted Arconic’s motion, entering judgment in favor of Arconic. Snyder appealed the decision to the Eighth Circuit.
Legal Analysis
Religious Discrimination Claim: The court first addressed Snyder’s religious discrimination claim under Title VII. To establish a prima facie case of religious discrimination, an employee must show: (1) a bona fide religious belief that conflicts with an employment requirement; (2) informing the employer of this belief; and (3) discipline for failing to comply with the conflicting employment requirement.
The court focused on the first element, finding it dispositive. While acknowledging that Snyder’s religious beliefs about the rainbow were bona fide and sincerely held, the court determined that Snyder failed to establish a conflict between his religious belief and Arconic’s employment requirements. The court emphasized that Snyder’s act of posting the comment on the company intranet was not motivated by or part of his religious beliefs. Instead, Snyder claimed it was an unintentional mistake.
The court deferred to Snyder’s own description of his beliefs and actions, concluding that the posting had no religious intent behind it and thus created no conflict with Arconic’s policies. The court noted that whether such a mistake should be grounds for termination was beyond the scope of their review.
Retaliation Claim: The court then addressed Snyder’s retaliation claim. To establish a prima facie case of retaliation, an employee must show: (1) engagement in protected conduct; (2) suffering an adverse employment action; and (3) a causal link between the protected conduct and the adverse action.
The court rejected Snyder’s argument that his intranet post was protected conduct, finding it objectively unreasonable to believe that Arconic’s limited use of the rainbow symbol created a Title VII-violating “abusive working environment.”
Alternatively, the court considered Snyder’s claim that he engaged in protected conduct during pre-termination disciplinary meetings. Even assuming this was protected conduct causally linked to his termination, the court found that Arconic offered a legitimate reason for termination: the intranet post and Snyder’s past policy violations.
The court concluded that Snyder failed to show that Arconic’s proffered reason was pretextual. Snyder’s references to a Hearing Letter and alleged hostility towards his religious beliefs were deemed insufficient to create a genuine factual dispute regarding pretext.
The Eighth Circuit affirmed the district court’s judgment, finding that Snyder failed to establish a prima facie case of religious discrimination and did not show that Arconic’s reasons for termination were pretextual in his retaliation claim.
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