Jeter v. Carr

CourtDistrict Court, N.D. Alabama
DecidedOctober 31, 2022
Docket2:20-cv-01863
StatusUnknown

This text of Jeter v. Carr (Jeter v. Carr) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeter v. Carr, (N.D. Ala. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

LANITRA JETER, ] ] Plaintiff, ] ] v. ] Case No.: 2:20-cv-01863-ACA ] DANNY CARR, ] ] Defendant. ]

MEMORANDUM OPINION AND ORDER While Plaintiff LaNitra Jeter, an African American woman, was working as a victims services officer in the Jefferson County District Attorney’s Office, she complained to District Attorney Danny Carr of racial discrimination because her supervisor disallowed her accrual of comp time. Four months after she made that complaint, Mr. Carr terminated her employment. Ms. Jeter filed a lawsuit asserting a number of claims against Mr. Carr in his official capacity but has conceded all but her claim of retaliatory termination in violation of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e-3(a). (Doc. 83 at 18). The rest of this court’s opinion will, therefore, address only the Title VII retaliatory termination claim. Mr. Carr moves for summary judgment. (Doc. 77). The court has considered the arguments and evidence submitted by the parties and GRANTS Mr. Carr’s motion because Ms. Jeter has not established: (1) a prima facie case of retaliation; (2) a dispute of material fact about whether the articulated reasons for terminating her employment were pretextual; or (3) a convincing mosaic of circumstantial

evidence from which a trier of fact could infer retaliatory intent. The WILL ENTER SUMMARY JUDGMENT in favor of Mr. Carr and against Ms. Jeter.

I. BACKGROUND When approaching a motion for summary judgment, the court “view[s] the evidence and all factual inferences therefrom in the light most favorable to the non- moving party, and resolve[s] all reasonable doubts about the facts in favor of the

non-movant.” Washington v. Howard, 25 F.4th 891, 897 (11th Cir. 2022). Danny Carr is the District Attorney of Jefferson County, Alabama. (Doc. 78- 1 at 9; doc. 78-4 at 6). The Victim Services Office is a unit of the District Attorney’s

Office for Jefferson County (doc. 78-4 at 105) that provides support for victims of crime during the prosecutorial process (doc. 78-3 at 7). During the time relevant to the allegations in this case, the Victim Services Office employed five victims services officers who were supervised by Judy Yates. (Doc. 78-8 at 3 ¶ 3, 4 ¶ 8).

Ms. Yates’s supervisor was Chief Deputy District Attorney Joe Roberts, who reported directly to Mr. Carr. (Doc. 78-6 at 4–5). Victim services officers could use three different types of leave to take time

off work: vacation leave, sick leave, and comp time. (Doc. 78-1 at 36). Victim services officers with accumulated leave time could use that time however they wished—although they generally needed to give advanced notice and Ms. Yates had

authority to deny requests for leave. (Id. at 38–40). Ms. Yates kept files on each victim services officer under her command and would update their files with memoranda detailing any workplace incidents involving that employee. (Id. at 51).

Mr. Carr testified that if an employee complained of discrimination by a supervisor, he would discuss the complaint with the supervisor in question. (Doc. 78-4 at 23). When an employee needed to be terminated, Mr. Carr was the final decision-maker. (Doc. 78-6 at 17).

LaNitra Jeter began work as a victims services officer in April 2019. (Doc. 78-3 at 7). During her first several months at the job, Ms. Jeter began suffering from health problems that caused her to seek help from a variety of specialists and

required her to use a substantial amount of leave time. (Id. at 15–16). In September 2019, the DA’s Office’s chief administrator, Michael McCurry, noted Ms. Jeter’s unusual use of her leave time and discussed this deviational use with Ms. Yates. (Doc. 78-8 at 9 ¶ 20). Over time, Ms. Yates and Mr. McCurry began to believe

Ms. Jeter was abusing the leave policy. (Id.; doc. 78-1 at 24). Based on Mr. McCurry’s recommendation, Ms. Yates informed Ms. Jeter that she would not be able to earn comp time for at least a week. (Doc. 78-1 at 41). Ms. Yates stated they would discuss whether Ms. Jeter could begin earning comp time again after the week was up. (Id.).

Shortly after, Ms. Jeter met with Ms. Yates and Mr. McCurry to discuss her comp time restriction. (Doc. 78-3 at 15). During the meeting, Ms. Jeter told Ms. Yates and Mr. McCurry that she believed they were singling her out and treating

her differently from the other victim services officers. (Id. at 16). At this meeting, Ms. Jeter expressed her opinion that, because she was the only African American victims services officer, applying different policies to her than other victims services officers was not fair. (Id. at 15–16).

On November 12, 2019, Ms. Jeter met with Mr. Carr to complain about her comp time being taken away. (Id. at 9). Mr. Carr testified that he does not recall this meeting but concedes that because Ms. Jeter testified that the meeting occurred, the

court must accept as true Ms. Jeter’s testimony. (Doc. 78-4 at 23; doc. 79 at 15). At this meeting, Ms. Jeter told Mr. Carr that she was being treated unfairly because she, the only African American victims services officer, was also the only victims services officer whose ability to earn comp time was restricted. (Doc. 78-3 at 10).

Ms. Yates was not present at this meeting and testified that she did not know about Ms. Jeter’s complaint until after her termination. (Doc. 78-11 at 5–6 ¶ 11). The same day that Ms. Jeter met with Mr. Carr, she requested to meet with Ms. Yates to discuss reinstating her ability to earn comp time. (Doc. 78-3 at 17). Ms. Yates allowed Ms. Jeter to begin accruing comp time again with some limits. (Id.).

Later in November, Ms. Jeter emailed Mr. Roberts asking to whom she should report her concern that she “d[id] not feel that [she was] being treated fairly in some situations.” (Doc. 78-6 at 51). Mr. Roberts responded that she should discuss any

concerns with Ms. Yates, who would reach back out to Mr. Roberts if necessary. (Id.). Ms. Jeter told Mr. Roberts that she would discuss her concerns with Ms. Yates the following day (id.), but that conversation never occurred (doc. 78-3 at 19). Mr. Roberts forwarded this email to Ms. Yates, who believed Ms. Jeter was

complaining about missing a domestic violence seminar that the other victim services officers attended. (Doc. 78-4 at 125). From the end of September until Ms. Jeter’s termination, Ms. Yates would

periodically update her supervisor, Mr. Roberts, on issues Ms. Jeter was having at work. (Doc. 78-6 at 16). These issues included incidents where Ms. Jeter left the office without permission (doc. 78-1 at 31–32), made accusatory statements to a victim that came to the Victims Services Office (id. at 23), was not working but also

not using comp time to make up for lost work hours (id. at 31), and was eating and sleeping in a courtroom during trial (id. at 20). Ms. Jeter has explanations for most of these incidents but does not deny that they took place. (Doc. 78-3 at 41–42, 44–

45, 55–56). After the incidents, Ms. Yates would update Ms. Jeter’s file with a report explaining what happened (doc. 78-1 at 45), but Ms. Jeter did not receive formal discipline for any of these issues (id. at 15–16).

In March 2020, in an attempt to successfully operate the DA’s Office during the COVID-19 outbreak, Mr. Roberts and Mr. Carr created a plan to limit the number of people physically present in the DA’s Office every day. (Doc. 78-4 at 61). Under

the plan, only one victims services officer would report to the DA’s Office each day, with individual officers rotating. (Id. at 61–62). After creating this plan, Mr. Roberts asked Ms. Yates to prepare a memo detailing Ms.

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