Estella L. Morris sued the Department of Veterans Affairs (VA) in the United States District Court for the Eastern District of Arkansas, raising claims of race discrimination and retaliation. The district court granted summary judgment to the VA, and Morris appealed the decision to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
Estella Morris, a black woman, began working for the Central Arkansas Veterans Healthcare System (CAVHS), a VA facility, in 1981 in the social work field. In 2015, Morris applied for the position of Chief of Social Work Service at CAVHS. She was one of two finalists, along with Anne Wright, a white woman. Despite Morris receiving a veteran preference, Wright was ultimately hired for the position.
The hiring official recommended Wright, citing her “excellent” references compared to Morris’s “good” references. The official noted concerns about Morris’s interpersonal skills and timeliness in responding to action items. Morris claimed that CAVHS failed to promote her because of her race and that the VA did not follow proper procedures for passing over a candidate with veteran preference.
Years later, Morris sought a pay upgrade due to changes in qualification standards. Her supervisor, Michael Ballard, submitted a request on her behalf, but Morris alleged that Ballard “sabotaged” her application in retaliation for her previous discrimination complaints. The upgrade was ultimately denied because Morris’s position did not meet the required complexity according to qualification standards.
Legal Analysis
Race Discrimination Claim: The court found that Morris had established a prima facie case of race discrimination but that CAVHS had provided a legitimate, non-discriminatory reason for promoting Wright over Morris. The burden then shifted to Morris to show that this reason was pretext for discrimination.
Morris argued that CAVHS’s failure to follow veteran preference pass-over procedures was evidence of pretext. The court rejected this argument, stating that without more, such a procedural oversight does not suggest that race affected the decision. The court affirmed summary judgment for CAVHS on the race discrimination claim.
Retaliation Claim: Morris alleged that her supervisor, Ballard, sabotaged her pay upgrade application in retaliation for her previous discrimination complaints. The court found no evidence to support a causal link between Morris’s protected activities and the denial of her pay upgrade. The court noted that Ballard had recommended the upgrade, and any errors in the application were corrected by Morris herself. Furthermore, the person who denied the upgrade was not shown to have knowledge of Morris’s protected activities.
The court affirmed the district court’s grant of summary judgment on both the race discrimination and retaliation claims.
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