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Garner v. Smith & Davis Manufacturing Co.

Citations: 625 F. Supp. 1385; 42 Empl. Prac. Dec. (CCH) 36,741; 1985 U.S. Dist. LEXIS 12189Docket: No. 84-2666C(4)

Court: District Court, E.D. Missouri; December 30, 1985; Federal District Court

Narrative Opinion Summary

The case involves a plaintiff, a white male, who filed a lawsuit against his employer, alleging racial discrimination under 42 U.S.C. 1981 and 42 U.S.C. 2000e following his discharge from a temporary assembly line position. The plaintiff argued that he was discriminated against because of his race when he was not hired for a full-time position, and a black male was chosen instead. During his employment, the plaintiff was aware of his temporary status, which did not grant union membership or bidding rights for other positions. The employer maintained a diverse workforce, with about 40% minority employees, and evaluated the plaintiff as a fair employee requiring improvement. The court determined that the plaintiff did not establish a prima facie case of racial discrimination, as there was no evidence that race influenced the hiring or discharge decisions. Consequently, the court dismissed the complaint, requiring each party to bear its costs, as the burden of proof, which lay with the plaintiff, was not met.

Legal Issues Addressed

Burden of Proof in Discrimination Cases

Application: The burden of proof rests with the plaintiff to demonstrate that race was a factor in the defendant's actions, which the plaintiff failed to do in this case.

Reasoning: The burden of proof lay with Garner, and he did not demonstrate that race was a factor in the actions taken by the defendant.

Employment Status and Rights under Collective Bargaining Agreements

Application: Temporary employees with less than 30 days at the company did not acquire seniority rights, affecting their employment claims.

Reasoning: Garner claimed he was not hired for a full-time position and was discriminated against due to his race when the company chose to hire a black male for a job he applied for, despite his temporary employment lasting less than 30 days, which conferred no seniority rights under the collective bargaining agreement.

Racial Discrimination under 42 U.S.C. 1981 and 42 U.S.C. 2000e

Application: The court applied the legal standard for establishing a prima facie case of racial discrimination and found that the plaintiff failed to meet this burden.

Reasoning: The court concluded that Garner failed to establish a prima facie case of racial discrimination, as there was no evidence indicating that race influenced his discharge or the hiring decisions.