Geddis v. University of Delaware

40 F. App'x 650
CourtCourt of Appeals for the Third Circuit
DecidedMarch 8, 2002
DocketNo. 01-2298
StatusPublished
Cited by12 cases

This text of 40 F. App'x 650 (Geddis v. University of Delaware) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geddis v. University of Delaware, 40 F. App'x 650 (3d Cir. 2002).

Opinion

[651]*651 OPINION OF THE COURT

SLOVITER, Circuit Judge.

Alexander Geddis, Jr., a white male, filed this suit claiming that his former employer, the University of Delaware, violated Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e et seq. (2001), by firing him from his job because of his race and gender, and violated the implied covenant of good faith and fair dealing that exists under Delaware law by misrepresenting his employment record. The District Court granted summary judgment for the University and Geddis appealed.

I.

BACKGROUND

Geddis was hired in 1988 by the University of Delaware as its Director of Support Services. On May 14, 1996, after various complaints about aspects of Geddis’ behavior had been made to University officials, he was advised he would be terminated effective May 31, 1996. In accordance with the University’s grievance procedures, Geddis pursued and exhausted all of his remedies within the University, losing at every step of the process.

Prior to Geddis’ termination, Charlene Benson, an African-American woman who was then an executive assistant to the Executive Vice-President of the University, was asked by Barbara Kreppel, Geddis’ immediate supervisor, to monitor Geddis’ conduct and performance. Thereafter, Benson was told to familiarize herself with the departments under Geddis’ supervision to learn the skills necessary to direct Support Services. After Geddis was terminated, the University appointed Benson to Geddis’ former position on an interim basis. Approximately five months later, she was permanently appointed Director of Support Services without an official executive search for other candidates. There is a dispute between the parties whether University policy required such a search.

On March 6, 1997, Geddis filed a charge of discrimination with the Equal Employment Opportunity Commission and the Delaware Department of Labor. Thereafter, on May 13, 1999, Geddis filed an eight-count complaint in the District Court. Subsequently, the parties agreed to the dismissal of all claims except those based on the grounds (a) that the University engaged in “reverse” race and gender discrimination in violation of Title VII when it terminated Geddis and replaced him with an African-American female and (b) that Geddis’ termination constituted a breach of Delaware’s implied covenant of good faith and fair dealing. The University then moved for summary judgment, which the District Court granted. Geddis appeals the District Court’s grant of summary judgment.

Because we write solely for the parties, we need not set forth a detailed recitation of the background for this appeal and will limit our discussion to resolution of the issues presented.

II.

JURISDICTION AND STANDARD OF REVIEW

The District Court had jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343, and supplemental jurisdiction over state claims pursuant to 28 U.S.C. § 1367. This court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1291 and 1294(1).

This court has plenary review of a grant of summary judgment pursuant to Federal Rule of Civil Procedure 56(c). This court must “examine the evidence of record in the light most favorable to ... the party opposing summary judgment, and resolve [652]*652all reasonable inferences in her favor.... This standard is applied with added rigor in employment discrimination cases, where intent and credibility are crucial issues.” Stewart v. Rutgers, The State University, 120 F.3d 426, 431 (3d Cir.1997) (quotation and citations omitted).

III.

DISCUSSION

A. Reverse Discrimination Claim

In the seminal case of McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973), the Supreme Court articulated a framework for evaluating Title VII employment discrimination claims when, as in most Title VII cases, there is little or no direct evidence of prohibited discrimination. This framework has been recently reviewed and clarified in Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000). Under this framework, a plaintiff claiming employment discrimination must first establish a prima facie case of discrimination. Once a plaintiff has done this, the burden of production shifts to the employer, who must produce evidence that the employment decision adverse to the plaintiff was made for a legitimate, non-discriminatory reason. Id. at 142. If the employer does this, then the burden shifts back to the employee/plaintiff to “demonstrate that the proffered reason was merely a pretext for unlawful discrimination.” Goosby v. Johnson & Johnson Med., Inc., 228 F.3d 313, 319 (3d Cir.2000) (citing Reeves, 530 U.S. at 143).

Typically, to establish a prima facie case of discrimination, a plaintiff must establish (i) membership in a protected class, (ii) adequate qualifications for the employment position in question, and (iii) that people who were not in the protected class were treated more favorably than those in the class. Goosby, 228 F.3d at 318-19. This showing is, however, ill-suited to claims involving alleged “reverse discrimination.” We have held that “the substance of the burden-shifting analysis applies with equal force to claims of ‘reverse discrimination,’ ” Iadimarco v. Runyon, 190 F.3d 151, 158 (3d Cir.1999), and that “all that should be required to establish a prima facie case in the context of ‘reverse discrimination’ is for the plaintiff to present sufficient evidence to allow a fact finder to conclude that the employer is treating some people less favorably than others based upon a trait that is protected under Title VII.” Id. at 161.

The University, for the limited purpose of its motion for summary judgment in the District Court, conceded that Geddis has established his prima facie case of discrimination. Geddis v. Univ. of Delaware, No. Civ. 99-304, 2001 U.S. Dist. LEXIS 9058, at *18, 2001 WL 536408 (D.Del. May 16, 2001). The District Court found, and Geddis does not deny, that the University has articulated a legitimate, non-discriminatory reason for its employment decision with respect to Geddis. Id. at *19.

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Bluebook (online)
40 F. App'x 650, Counsel Stack Legal Research, https://law.counselstack.com/opinion/geddis-v-university-of-delaware-ca3-2002.