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McNeill v. RDH & PEM Investments, L.L.C.
Citation: 31 F. App'x 880Docket: No. 01-1482
Court: Court of Appeals for the Sixth Circuit; March 20, 2002; Federal Appellate Court
Roszetta Marie McNeill, representing herself, appeals a district court decision that granted summary judgment to RDH PEM Investments, L.L.C. in her claims under Title VII of the 1964 Civil Rights Act, the Americans with Disabilities Act (ADA), and the Fair Housing Act (FHA). McNeill, an African-American woman with lupus and thrombocytopenia, alleged discrimination based on race and disability, retaliation, and violations of fair housing rights due to her termination and eviction. The district court found that McNeill did not present direct evidence of discrimination or establish a prima facie case for her claims, concluding that her allegations were insufficient and lacked corroborative evidence. The court noted that although she was a member of a protected class under Title VII, she did not meet the criteria for ADA protections. Additionally, McNeill was replaced by another African-American employee and failed to identify any similarly situated individuals treated more favorably. Her retaliation claim was undermined by her acknowledgment that she did not contact any government agency regarding her discrimination claims before her termination, eliminating a causal link. Regarding her FHA claim, the court determined that her eviction was based on non-payment of rent, which did not constitute a fair housing violation. Ultimately, the appellate court affirmed the district court's ruling, finding no genuine issues of material fact that would preclude summary judgment for RDH.