Jackson v. Saint Charles County, Missouri

CourtDistrict Court, E.D. Missouri
DecidedJanuary 25, 2022
Docket4:20-cv-01504
StatusUnknown

This text of Jackson v. Saint Charles County, Missouri (Jackson v. Saint Charles County, Missouri) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jackson v. Saint Charles County, Missouri, (E.D. Mo. 2022).

Opinion

EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

KEVIN JACKSON, ) ) Plaintiff, ) ) vs. ) Case No. 4:20 CV 1504 RWS ) SAINT CHARLES COUNTY, ) MISSOURI, ) ) Defendant. )

MEMORANDUM AND ORDER

Plaintiff Kevin Jackson (“Jackson”) was employed by Defendant Saint Charles County, Missouri (“the County”) from 2002 until 2019. On October 16, 2020, Jackson filed a complaint against the County, alleging that he experienced racial discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.; the Civil Rights Act of 1866, 42 U.S.C. § 1981; and the Missouri Human Rights Act, Section 2013.010 R.S.Mo. et seq. (“MHRA”) while working as a County police officer. The County has moved for summary judgment. For the reasons explained below, I will grant the County’s motion. LEGAL STANDARD Summary judgment is appropriate if the evidence, viewed in the light most favorable to the nonmoving party, demonstrates that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law. Lynn v. Deaconess Med. Ctr.–West Campus, 160 F.3d 484, 486 (8th Cir. 1998) responsibility of informing the court of the basis of its motion and identifying those portions of the affidavits, pleadings, depositions, answers to interrogatories, and admissions on file which it believes demonstrates the absence of a genuine issue of

material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). When such a motion is made and supported by the movant, the nonmoving party may not rest on his pleadings but must produce sufficient evidence to support the existence of the essential elements of his case on which he bears the burden of proof. Id. at 324. In

resisting a properly supported motion for summary judgment, the plaintiff has an affirmative burden to designate specific facts creating a triable controversy. Crossley v. Georgia-Pacific Corp., 355 F.3d 1112, 1113 (8th Cir. 2004).1

Because direct evidence of employment discrimination is rare, most cases rely on circumstantial evidence. In the absence of direct evidence of discrimination, courts employ the burden shifting analysis of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (Title VII case). Under this burden-shifting analysis, the

plaintiff must first establish a prima facie case of intentional discrimination. Id. at 802; Bashara v. Black Hills Corp., 26 F.3d 820, 823 (8th Cir. 1994). If the plaintiff

1 In his opposition brief, Jackson recites the principle that summary judgment should rarely be granted in employment discrimination cases, citing Daugherty v. City of Maryland Heights, 231 S.W.3d 814, 818 (Mo. banc 2007) in support. While this was once the law, there is now “no discrimination case exception to the application of summary judgment.” Torgerson v. City of Rochester, 643 F.3d 1031, 1043 (8th Cir. 2011) (citations omitted).

2 burden of production shifts to the defendant to articulate a legitimate, non- discriminatory reason for the adverse employment action. McDonnell Douglas, 411 U.S. at 802. The defendant need not persuade the court that the articulated reason

was the basis of the employer’s action; rather, it must simply provide some evidence of a non-discriminatory reason or reasons for its action. St. Mary’s Honor Center v. Hicks, 509 U.S. 502, 509 (1993). Upon the proffer of such evidence, the presumption of discrimination

established by the prima facie case “simply drops out of the picture.” Id. at 510-11. The burden then shifts back to the plaintiff to prove that the reason articulated by the employer was really a pretext for discrimination. Aucutt v. Six Flags Over Mid-

America, Inc., 85 F.3d 1311, 1316 (8th Cir. 1996). A rejection of the employer’s proffered non-discriminatory reason by itself or combined with elements of the prima facie case may be enough to establish, but does not compel, an inference of intentional discrimination. St. Mary’s Honor Center, 509 U.S. at 511.

The burden of proving discrimination remains on the plaintiff at all times. Id. at 515-16. It is not enough to merely discredit the defendant’s articulated reason for the adverse employment action. A plaintiff must always establish that the real reason

for the defendant’s action was impermissible discrimination. Id.; see also Huston v. McDonnell Douglas Corp., 63 F.3d 771, 777 (8th Cir. 1995). To avoid summary

3 (1) creates a fact issue as to whether the employer’s proffered reason is pretextual, and (2) creates a reasonable inference that a discriminatory motive was a determinative factor in the adverse employment decision. Rothmeier v. Investment

Advisers, Inc., 85 F.3d 1328, 1336-37 (8th Cir. 1996). BACKGROUND Jackson, who is African American, was employed by the County from 2002 until October 2019. He worked for the County Department of Corrections from 2002

until 2007 and then transferred to the County Sheriff’s Department. When the Sheriff’s Department reorganized into two entities in 2015, Jackson transferred to the County Police Department, where he remained until his resignation on October

30, 2019. [Doc. # 23-6, Ex. F]. During his entire tenure with the County, Jackson applied for one special assignment and received it. [Doc. # 31-1, Ex. 1, Jackson Dep. 180:22-25]. At the end of his career with the County, he held the rank of patrolman. [Id. at 59:13].

On October 21, 2019, Captain Christopher Hunt, who served as the Department’s Commander of the Bureau of Administrative Services, delivered a Notice of Proposed Severe Discipline to Jackson. [Doc. # 23-4, Ex. D, Hunt Aff.

¶ 3-4]. The notice informed Jackson that he faced termination as a result of violating multiple departmental policies, including neglect of duty, lying to a supervisor, and

4 The County initially issued the Notice of Proposed Severe Discipline because Jackson filed two late reports. [Doc. # 23-5, Ex. E]. Officers are supposed to complete reports within 24 hours after they are drawn; failure to do so constitutes a violation of departmental policy.2 [Doc. # 31-1, Ex. 1, Jackson Dep. 81:1]. Jackson

acknowledges that he did not file all of his reports within the 24-hour timeframe. However, he contends, and the County admits, that officers do not always file their reports on time. When this happens, “supervisors would usually leave a note on the

overdue screen of the report writing system to get the report done ASAP.” [Doc. # 28, ¶ 33]. When Captain Koch contacted Jackson about scheduling a meeting with

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Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Hazelwood School District v. United States
433 U.S. 299 (Supreme Court, 1977)
Watson v. Fort Worth Bank & Trust
487 U.S. 977 (Supreme Court, 1988)
St. Mary's Honor Center v. Hicks
509 U.S. 502 (Supreme Court, 1993)
Harris v. Forklift Systems, Inc.
510 U.S. 17 (Supreme Court, 1993)
Oncale v. Sundowner Offshore Services, Inc.
523 U.S. 75 (Supreme Court, 1998)
Torgerson v. City of Rochester
643 F.3d 1031 (Eighth Circuit, 2011)
Bennett v. Nucor Corp.
656 F.3d 802 (Eighth Circuit, 2011)
Ellis Crossley v. Georgia-Pacific Corporation
355 F.3d 1112 (Eighth Circuit, 2004)
Mischelle Richter v. Advance Auto Parts
686 F.3d 847 (Eighth Circuit, 2012)
Daugherty v. City of Maryland Heights
231 S.W.3d 814 (Supreme Court of Missouri, 2007)
Denise Blomker v. Sally Jewell
831 F.3d 1051 (Eighth Circuit, 2016)

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Jackson v. Saint Charles County, Missouri, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-saint-charles-county-missouri-moed-2022.