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Parley F. Banks v. City of Independence, Missouri Larry Kaufman, as an Individual and as Acting City Manager, City of Independence, Missouri William Carpenter, as an Individual and as Mayor, City of Independence, Missouri William McDonald as an Individual and as Councilmember, at Large, City Council, City of Independence, Missouri Penny D. Bennett, as an Individual and as Councilmember, at Large, City Council, City of Independence, Missouri Lyle R. Weeks, as an Individual and as Councilmember, District 1, City Council, City of Independence, Missouri Victor E. Callahan Robert W. Clothier, as an Individual and as Councilmember, District 3, City Council, City of Independence, Missouri and James R. Ruhlman, as an Individual and as Councilmember, District 4, City Council, City of Independence, Missouri
Citations: 21 F.3d 809; 1994 U.S. App. LEXIS 7040; 64 Fair Empl. Prac. Cas. (BNA) 767Docket: 93-2221
Court: Court of Appeals for the Eighth Circuit; April 12, 1994; Federal Appellate Court
Parley Banks appeals the grant of summary judgment to the City of Independence, Missouri, regarding his federal and state age discrimination claims. Banks contends that the trial court applied an incorrect standard for summary judgment and overlooked certain evidence when making its decision. He also challenges the denial of his motion for reconsideration based on newly discovered evidence. The appellate court affirms the trial court's decision. Both parties agree that the analytical framework for race discrimination under Title VII is applicable to age discrimination claims under the Age Discrimination in Employment Act and Missouri human rights statutes. The trial court's summary judgment was based on two key findings: first, that Banks failed to establish a prima facie case of age discrimination in his termination; and second, that Banks did not present sufficient direct evidence of age discrimination to warrant a different legal standard, as he argued should be applied based on precedential cases like Price Waterhouse v. Hopkins and Trans World Airlines, Inc. v. Thurston. The court finds that the procedural scheme is not the focus, referencing the United States Postal Service Board of Governors v. Aikens case, which emphasizes the importance of determining whether a genuine issue of discrimination exists. The trial court's summary judgment was based on this ultimate question. Upon reviewing the evidence, including affidavits and depositions, the court agrees with the trial court that Mr. Banks did not demonstrate a genuine issue of material fact regarding discriminatory intent from the city. Much of Mr. Banks' evidence was deemed irrelevant, with no indication that age played a role in his job termination. The court also notes Mr. Banks' admission that political maneuvering could have prevented his job loss, reinforcing the trial court's decision. Mr. Banks' motion for reconsideration based on new evidence from another case was denied, with the court finding no abuse of discretion in that denial. The judgment of the trial court is affirmed.