Case: Discrimination/Race Discrimination (W.D. Mo.)

A Missouri federal district court granted Union Pacific Railroad’s renewed motion for summary judgment on race discrimination and retaliation claims under 42 U.S.C. § 1981 brought by a Black material handler/yard office coordinator, finding that although her increased workload could constitute an adverse employment action under the Supreme Court’s Muldrow standard, the circumstances didn’t support an inference of discrimination since her supervisor mistreated all employees regardless of race, and her retaliation claim failed due to lack of causal connection between her protected activity and any adverse action.

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