Karen Francois v. Acadiana Security Plus, Inc.

CourtLouisiana Court of Appeal
DecidedFebruary 13, 2008
DocketCA-0007-1112
StatusUnknown

This text of Karen Francois v. Acadiana Security Plus, Inc. (Karen Francois v. Acadiana Security Plus, Inc.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Karen Francois v. Acadiana Security Plus, Inc., (La. Ct. App. 2008).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

07-1112

KAREN FRANCOIS

VERSUS

ACADIANA SECURITY PLUS, INC., ET AL.

********** APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2006-0209 HONORABLE JOHN D. TRAHAN, DISTRICT JUDGE **********

GLENN B. GREMILLION JUDGE

**********

Court composed of Glenn B. Gremillion, Elizabeth A. Pickett, and J. David Painter, Judges.

AFFIRMED.

L. Clayton Burgess Lauren K. Ledet P. O. Drawer 5250 Lafayette, LA 70502-5250 (337) 234-7573 Counsel for Plaintiff/Appellant: Karen Francois Stephen J. Oats Patrick B. McIntire George O. Luce Oats & Hudson 100 E. Vermilion, Suite 400 Lafayette, LA 70501 (337) 233-1100 Counsel for Defendant/Appellee: Acadiana Security Plus, Inc. GREMILLION, Judge.

The plaintiff, Karen Francois, appeals the trial court’s grant of summary

judgment in favor of the defendant, Acadiana Security Plus, Inc., dismissing with

prejudice her claims of racial discrimination based on a hostile work environment and

constructive discharge. We affirm.

FACTS

Francois, who is African-American, worked part-time, one day a week,

as a dispatcher for Acadiana Security. On January 16, 2005, two pages of racially

offensive jokes aimed at African-Americans were left on the dispatcher desk which

she used. Acadian Security has a written policy against racial discrimination.

Francois complained about the jokes to her supervisors, Paul Courts and Tim

Begnaud, and to owner, Larry Comeaux. The identity of the employee responsible

for the jokes was determined, and that employee later apologized to Francois.

On January 13, 2006, Francois filed suit against Acadiana Security

seeking damages for racial discrimination/harassment and intentional/negligent

infliction of emotional distress. In her petition, she relied on not only the racially-

oriented jokes, but also statements made by Begnaud in which he stated, “Hey my

n_____.” As of that date, Francois was still employed by Acadiana Security. She

resigned in March 2006, after she was contacted by Courts about dropping her

lawsuit.

In response to her suit, Acadiana Security filed an answer and a motion

for summary judgment arguing that Francois would be unable to prove essential

elements of her claims for racial discrimination based on a hostile workplace,

1 constructive discharge, and intentional/negligent infliction of emotional distress.

Following a hearing, the trial court granted summary judgment in favor of Acadiana

Security and dismissed Francois’ claims with prejudice. This appeal by Francois

followed.

ISSUES

On appeal, Francois argues that the trial court erred in granting summary

judgment in favor of Acadiana Security and dismissing her claims for racial

discrimination based on hostile work environment and constructive discharge. She

does not appeal the trial court’s ruling with regard to her claims for

intentional/negligent infliction of emotional distress.

SUMMARY JUDGMENT

The standard of review in summary judgment cases is well settled.

La.Code Civ.P. art. 966. Pursuant to Article 966(C)(2), if the mover will not bear the

burden of proof at trial, then he is only required to “point out to the court that there

is an absence of factual support for one or more elements essential to the adverse

party’s claim, action, or defense.” Upon this showing, the burden then shifts to the

adverse party to produce evidence establishing “that he will be able to satisfy his

evidentiary burden of proof at trial.” Id. The threshold question in reviewing a trial

court’s grant of summary judgment is whether a genuine issue of material fact

remains. Kumpe v. State, 97-386 (La.App. 3 Cir. 10/8/97), 701 So.2d 498, writ

denied, 98-0050 (La. 3/13/98), 712 So.2d 882.

RACIAL DISCRIMINATION

In her two assignments of error, Francois argues that the trial court erred

2 in finding that she would be unable to prove essential elements in her racial

discrimination claims based on hostile work environment and constructive discharge.

In addition to the two pages consisting of eighteen racial jokes, Francois

complains about statements made by Begnaud and another employee. Begnaud’s

statement, “Hey my n_____,” was directed to Melanie Citizen, another African-

American employee of Acadiana Security. Citizen related the statement to Francois

after Francois complained about the racial jokes left on her desk. The other alleged

racially discriminatory comment was made by Thelma, another co-worker, to

Begnaud in Francois’ presence. Thelma stated that she passed a Shoney’s Restaurant

that morning and noted that there were a hundred black people and two cop cars

present. Francois stated that she thought Thelma made the comment in order to show

her support for Acadiana Security.

Louisiana Revised Statutes 23:332(A) provides that it shall be unlawful

for an employer to:

(1) Intentionally fail or refuse to hire or to discharge any individual, or otherwise to intentionally discriminate against any individual with respect to his compensation, or his terms, conditions, or privileges of employment, because of the individual’s race, color, religion, sex, or national origin.

(2) Intentionally limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities, or otherwise adversely affect his status as an employee, because of the individual’s race, color, religion, sex, or national origin.

As this statute is similar to Title VII of the Civil Rights Act of 1964, Louisiana courts

have availed themselves of decisions found in federal jurisprudence when interpreting

claims pursuant to Section 332. Hicks v. Cent. La. Elec. Co., Inc., 97-1232 (La.App.

3 1 Cir. 5/15/98), 712 So.2d 656. This includes cases dealing with sexual harassment,

which are reviewed under the same standard as those pertaining to racial harassment.

Chaney v. Home Depot, USA, Inc., 05-1484 (La.App. 4 Cir. 8/16/06), 940 So.2d 18,

writ denied, 06-2286 (La. 11/22/06), 942 So.2d 559.

In order to prevail on her hostile work environment claim, Francois must

prove five elements: 1) she belonged to a protected group; 2) that she was subjected

to harassment; 3) that the harassment was motivated by discriminatory animus (race);

4) that the harassment affected a term, condition, or privilege of employment; and 5)

that the employer knew or should have known of the harassment and failed to take

proper remedial action. Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337 (5th

Cir. 2007); Chaney, 940 So.2d 18. “A hostile work environment is one that does not

affect an employee’s economic benefits, but instead creates a hostile or offensive

working environment.” Hicks, 712 So.2d at 658.

In Faragher v. City of Boca Raton, 524 U.S. 775, 787-88, 118 S.Ct.

2275, 2283-84 (1998) (citations omitted), the Supreme Court explained:

[I]n order to be actionable under the statute, a sexually objectionable environment must be both objectively and subjectively offensive, one that a reasonable person would find hostile or abusive, and one that the victim in fact did perceive to be so.

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Related

Turner v. Baylor Richardson Medical Center
476 F.3d 337 (Fifth Circuit, 2007)
Faragher v. City of Boca Raton
524 U.S. 775 (Supreme Court, 1998)
Pennsylvania State Police v. Suders
542 U.S. 129 (Supreme Court, 2004)
Chaney v. Home Depot, USA, Inc.
940 So. 2d 18 (Louisiana Court of Appeal, 2006)
Kumpe v. State
701 So. 2d 498 (Louisiana Court of Appeal, 1997)
Hicks v. Central Louisiana Elec. Co., Inc.
712 So. 2d 656 (Louisiana Court of Appeal, 1998)

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