Robert Riggs v. Kansas City Missouri Public School District
Docket: 03-3091
Court: Court of Appeals for the Eighth Circuit; October 20, 2004; Federal Appellate Court
Robert Riggs appealed a judgment from the District Court for the Western District of Missouri favoring the Kansas City, Missouri, Public School District regarding his employment discrimination claims. Riggs contended that the court improperly granted summary judgment on his discriminatory discharge claim and erred by denying his motion for a new trial related to his discriminatory promotion claim. The Eighth Circuit Court, with Circuit Judge McMillian writing for the panel, affirmed the lower court’s decision.
Riggs, an Asian-American, was employed by the District from 1991 until his discharge in December 2001. He initially worked in student recruitment and public relations before becoming a staffing specialist in 1998. In August 2000, he was promoted to director of recruiting and staffing by Cynthia Clegg, the executive director of human resources.
In April 2001, after the District lost its state accreditation, Superintendent Benjamin Demps and several staff members resigned, leading to Dr. Bernard Taylor's appointment as interim superintendent. Taylor appointed Brenda Thomas, an African-American employee relations manager, as interim executive director of human resources without considering other candidates due to their prior working relationship.
In July 2001, the District advertised for a permanent executive director of human resources, requiring a bachelor’s degree in a relevant field. Both Riggs and Thomas applied; however, Taylor later decided not to fill the position permanently, allowing Thomas to continue as interim director. Riggs, now under Thomas's supervision, faced multiple performance complaints, leading to a written warning from Thomas on August 17, 2001, for failing to produce a required staffing manual and not following her directives.
Despite the warning, complaints about Riggs's performance persisted, including issues with leadership, sharing personal information about colleagues, and lack of cooperation with a consultant. Ultimately, Thomas terminated Riggs on December 31, 2001, citing noncompliance with directives, failure to correct previous issues, and inadequate support for his staff.
In February 2002, Riggs filed a complaint alleging racial discrimination under Title VII and related laws, claiming he was denied promotion to executive director of human resources and wrongfully terminated due to his Asian ethnicity. The District successfully moved for summary judgment on the discharge claim, with the court concluding Riggs did not establish a prima facie case nor demonstrate that the District's reasons for his termination were a pretext for discrimination. However, the motion was denied concerning the promotion claim. At trial, Riggs declined the opportunity for a mixed-motive jury instruction, and the instruction given favored the District, resulting in the jury's verdict for the District. Following the Supreme Court's ruling in Desert Palace, which stated that direct evidence is not necessary for a mixed-motive instruction, Riggs sought a new trial, but the district court denied it, citing Riggs's prior decision to forgo the mixed-motive instruction.
Riggs contended the district court erred in granting summary judgment on his discharge claim, but the appellate review affirmed the lower court's decision, emphasizing that Riggs failed to meet the legitimate expectations of his employer and did not present sufficient evidence to demonstrate that the reasons for his termination were pretextual. Although he argued that discriminatory attitudes existed within the workplace, the evidence provided related to preferences for African-American appointments did not indicate that the District's legitimate reasons for his termination were false. Furthermore, the jury had already rejected similar evidence regarding discrimination in the promotion claim.
Riggs contends that he was discharged by Thomas to remove competition for the executive director position in the human resources department, claiming he was more qualified. However, the argument lacks merit since even if true, it does not demonstrate that the discharge was racially motivated. The district court noted that if Riggs's assertion were valid, Thomas would not need to discharge him as he is not African-American, and the timing of the discharge, occurring four and a half months after his application, does not suggest racial discrimination.
Additionally, Riggs's appeal for reversal of the summary judgment based on the Desert Palace ruling, which allows for mixed-motive instruction without direct evidence, is rejected. The court indicated that Riggs failed to provide any evidence, direct or circumstantial, to suggest that race was a motivating factor in his termination.
Moreover, the district court's denial of Riggs's motion for a new trial regarding his promotion claim is upheld since Riggs waived this issue during the instruction conference by declining the mixed-motive factor. The court concludes that this case does not warrant exceptional reversal. Ultimately, the judgment of the district court is affirmed.
