Thompson v. Conagra Brands Inc

CourtDistrict Court, E.D. Arkansas
DecidedJanuary 16, 2025
Docket4:21-cv-01133
StatusUnknown

This text of Thompson v. Conagra Brands Inc (Thompson v. Conagra Brands Inc) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. Conagra Brands Inc, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION WANDA FAYE THOMPSON PLAINTIFF v. CASE NO. 4:21-CV-01133-BSM CONAGRA BRANDS, INC. DEFENDANT

ORDER Conagra Brands Inc.’s motion for summary judgment [Doc. No. 106] is granted, Wanda Thompson’s motion for summary judgment [Doc. No. 114] is denied and Thompson’s second amended complaint [Doc. No. 51] is dismissed with prejudice.

I. BACKGROUND Thompson is suing Conagra for race discrimination under 42 U.S.C. section 1981 and for retaliation. Both Conagra and Thompson are moving for summary judgment. Conagra has presented verified testimony in support of its motion and in opposition to Thompson’s motion. Dec. Jerry Rodgers, Doc. No. 108-1; Dec. Jasmine Ornelas, Doc. No. 108-2.

Thompson has failed to submit verified testimony in support of her motion and in response to Conagra’s motion. This is typically fatal at summary judgment because only evidence, and not allegations and arguments, can be considered in deciding motions for summary judgment. Vanegas v. Carleton Coll., 575 F. Supp. 3d 1112, 1126 (D. Minn. 2021) (Citing Quinn v. St. Louis County, 653 F.3d 745, 752 (8th Cir. 2011)); cf. Lujan v. Defs. of Wildlife,

504 U.S. 555, 561 (1992). Because Thompson is pro se and has signed all of her pleadings, I considered viewing those somewhat confusing documents as having been verified. See Jones v. Blanas, 393 F.3d 918, 923 (9th Cir. 2004) (recognizing that pro se contentions, based on personal knowledge, offered in motions and pleadings may be considered evidence). Conagra, however, attempted to clarify Thompson’s pleadings through

interrogatories and deposition. Thompson’s answers to Conagra’s interrogatories were either unresponsive or deficient. Pl. Answer Interrog. at 5–8, Doc. No. 95. Regarding her deposition, she failed to appear and had no reasonable explanation for why she failed to appear. See Br. Supp. Mot. Sanctions ¶ 20 Doc. No. 101. (canceling her deposition on the

morning it was scheduled because, “her mind was not stable to answer any questions”). It would, therefore, be unjust to consider her complaint and pleadings as having been verified when she failed to appear and provide testimony under oath. Consequently, based on the verified evidence in the record, the undisputed facts are as follows. Wanda Thompson was an hourly employee at Conagra from 1994 to 2021. Def.

Statement of Uncontroverted Material Facts ¶¶ 29, 65, Doc. No. 108 (“SUMF”). She was fired in February of 2017 but, with union representation, was reinstated in June of 2018 with higher pay. Id. ¶¶ 36, 37, 40, 46, 51, 54. Approximately four years after Thompson’s reinstatement, Conagra restructured its operations and eliminated two team coordinator positions. Id. ¶¶ 55, 57. One position was held by Thompson, a black woman, and the other

was held by a non-black employee. Id. ¶ 54. The duties performed by Thompson and the other team coordinator were redistributed to at least three other supervisors. Id. ¶ 58. Thompson worked in two different positions over the course of the next two years and then retired. Id. ¶¶ 63–65.

2 II. LEGAL STANDARD Summary judgment is appropriate when there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law. See Fed. R. Civ.

P.56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249–50 (1986). Once the moving party shows that there is no genuine dispute of material fact, the non-moving party may not rest upon the mere allegations or denials in her pleadings. Holden v. Hirner, 663 F.3d 336, 340 (8th Cir. 2011). Instead, the non-moving party must produce admissible evidence

demonstrating a genuine factual dispute requiring a trial. Id. All reasonable inferences must be drawn in a light most favorable to the non-moving party. Holland v. Sam’s Club, 487 F.3d 641, 643 (8th Cir. 2007). The evidence is not weighed, and no credibility determinations are made. Jenkins v. Winter, 540 F.3d 742, 750 (8th Cir. 2008). III. DISCUSSION

Conagra’s motion for summary judgment is granted. A. Race Discrimination To make out a prima facie case of race discrimination, Thompson must show: (1) she is a member of a protected class, (2) she met Conagra’s legitimate expectations, (3) she suffered an adverse employment action, and (4) discrimination can be inferred from the

circumstances. Watson v. McDonough, 996 F.3d 850, 855 (8th Cir. 2021) (citations omitted). In a section 1981 case, the plaintiff must also prove that race was a but-for cause of her termination. Comcast Corp. v. Nat’l Ass’n of Afr. Am.-Owned Media, 589 U.S. 327, 340–41 (2020).

3 It is undisputed that Thompson is a member of a protected class and was meeting Conagra’s expectations. Conagra, however, argues that Thompson did not suffer an adverse employment action and discrimination cannot be inferred from the circumstances.

1. Adverse Employment Action “An adverse employment action is a disadvantageous change to the compensation, terms, conditions, or privileges of employment.” Cole v. Grp. Health Plan, Inc., 105 F.4th 1110, 1114 (8th Cir. 2024) (citing Muldrow v. St. Louis, 601 U.S. 346 (2024); 42 U.S.C. §

2000e-2(a)). Any claim that the 2017 termination was discriminatory is time-barred. See Order Granting Motion to Dismiss at 3, Doc. No. 63. Moreover, the record shows that at the time of Thompson’s 2018 reinstatement, she was put back in her original position with higher pay. SUMF ¶¶ 36, 46, 51, 54; Declaration of Jerry Rodgers ¶ 34, Doc. No. 108-1. She, therefore, cannot show she experienced an adverse action in 2018.

In 2021, Conagra restructured and eliminated Thompson’s position. SUMF ¶¶ 55, 58. Limited details about the new position are provided, so it is difficult to determine whether Thompson’s reassignment disadvantaged her. Construing the record in the light most favorable to Thompson, and giving her a significant benefit of the doubt, it appears that her new job title was junior to her former job title. Id. ¶¶ 62, 63 (changing job title from Team

Coordinator to Utility Prep). Consequently, the record indicates that she may have suffered an adverse employment action after the 2021 restructuring. 2. Inference of Discrimination Thompson must also show that race discrimination can be inferred from Conagra’s

4 2021 restructuring. Thompson’s position was not the only one eliminated. SUMF ¶¶ 54, 57. A non-black employee’s position was also eliminated, which undermines any inference that Thompson’s race was the motivation for the restructuring. Valencia v. U.S. Bank Nat'l Ass'n,

No. 4:18-CV-56, 2019 WL 9821776, at *9 (S.D. Iowa Aug. 19, 2019) (no prima facie discrimination when employees of different races have their employment eliminated during restructuring). Moreover, Thompson’s duties were redistributed to at least two other employees, whose race is unknown.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Quinn v. St. Louis County
653 F.3d 745 (Eighth Circuit, 2011)
Holden v. Hirner
663 F.3d 336 (Eighth Circuit, 2011)
Oscar W. Jones v. Lou Blanas County of Sacramento
393 F.3d 918 (Ninth Circuit, 2004)
Katharina Holland v. Sam's Club
487 F.3d 641 (Eighth Circuit, 2007)
Takele v. Mayo Clinic
576 F.3d 834 (Eighth Circuit, 2009)
Jenkins v. Winter
540 F.3d 742 (Eighth Circuit, 2008)
Lana Starkey v. Amber Enterprises, Inc.
987 F.3d 758 (Eighth Circuit, 2021)
Monica Watson v. Denis McDonough
996 F.3d 850 (Eighth Circuit, 2021)
Constance A. Onyiah v. St. Cloud State University
5 F.4th 926 (Eighth Circuit, 2021)
Pamela Cole v. Group Health Plan, Inc.
105 F.4th 1110 (Eighth Circuit, 2024)

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Bluebook (online)
Thompson v. Conagra Brands Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-conagra-brands-inc-ared-2025.