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Miranda v. Jetro Cash & Carry Enterprises, Inc.
Citation: 336 F. App'x 23Docket: No. 07-2320-cv
Court: Court of Appeals for the Second Circuit; July 2, 2009; Federal Appellate Court
Hubert Miranda, the plaintiff-appellant, appeals a May 14, 2007 judgment from the District Court that granted summary judgment in favor of Jetro Cash & Carry Enterprises, Inc., his employer. Miranda alleged demotion due to discrimination based on his ethnicity (Garifuna) and national origin (Belize) under Title VII of the Civil Rights Act of 1964. He represented himself throughout the proceedings. The appeals court reviewed the District Court’s grant of summary judgment de novo, adhering to Rule 56 of the Federal Rules of Civil Procedure, which mandates that facts be viewed in favor of the non-moving party. Summary judgment is appropriate only when there are no genuine issues of material fact and the movant is entitled to judgment as a matter of law. The court applied the burden-shifting framework established in McDonnell Douglas Corp. v. Green, which requires a plaintiff to present evidence of a prima facie discrimination claim. If successful, the burden shifts to the employer to provide legitimate, nondiscriminatory reasons for the adverse employment action. If the employer does so, the burden shifts back to the plaintiff to show that these reasons are pretexts for discrimination. The appellate court concurred with the District Court’s findings, stating that even if Miranda could establish the prima facie elements of his claim, he failed to provide evidence indicating that Jetro's stated legitimate business reasons for his termination were actually pretexts for discrimination. The record indicated Miranda received multiple reprimands leading up to his termination, with no evidence suggesting these actions were motivated by discrimination. Additionally, the court found Miranda's other arguments, including claims of bias against the District Court, to lack merit. Consequently, the court affirmed the District Court's judgment.