Law School Case Brief
Mosley v. Gen. Motors Corp. - 497 F. Supp. 583 (E.D. Mo. 1980)
Under Title VII of the Civil Rights Act of 1964, the plaintiffs have the initial burden of proving a prima facie case. If the plaintiffs satisfy this burden, the defendant must then articulate a legitimate, non-discriminatory reason for its actions. The plaintiffs then are given an opportunity to show that the articulated reason is merely a pretext for illicit discrimination.
Plaintiffs Mosley and Lumpkins, who were African-American, were hired by defendant General Motors Corp. ("GM"), but not when they first filed applications. Plaintiff Centers, who was also African-American, sought a position with GM as an inspector or clerk, but he was hired as a polisher; his efforts to transfer to an inspector or clerk position failed because those positions usually were given out based on seniority. All plaintiffs were members of defendants International Union, United Automobile, Aerospace and Agricultural Implement Workers of America and its Local 25 (collectively, "Union"). Plaintiffs claimed to experience discriminatory conduct and filed grievances with the Union. Plaintiffs were also disciplined for participating in a wildcat strike initiated by plaintiffs and other African-American employees over discrimination issues. Plaintiffs filed complaints with the Equal Employment Opportunity Commission, and they each obtained right to sue letters. Thereafter, plaintiffs filed a lawsuit against defendants in federal district alleging discrimination account of their race and retaliation for engaging in protests of defendants' unlawful discriminatory practices.
Did the discrimination and retaliation claims have merit?
The court, in its findings of fact and conclusions of law, largely denied plaintiffs' claims. There was no evidence of discrimination. The various employment decisions were largely based on a bona fide seniority system and the labor contract between GM and the Union. There was no evidence that the Union failed to pursue plaintiffs' grievances. However, the discipline after the wildcat strike was discriminatory in that plaintiffs were subjected to harsher punishments than similarly situated white employees. White employees who engaged in other work stoppages had their records cleared. For the same reasons, the retaliation claims had merit. Plaintiffs were subjected to harsher discipline for protesting racial concerns than other employees protesting other work issues. However, the court noted that the Union acted properly in all respects and was not liable on any of plaintiffs' discrimination and retaliation claims.
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