Haynes v. Waste Connections (Gregory 04/23/19): The Fourth Circuit held that Haynes had pointed to sufficient disputes of fact in the record to establish a prima facie case of discriminatory treatment under Title VII. The Circuit Court also found that Haynes had put forward sufficient evidence for the factfinder to find pretext. The Fourth Circuit reviewed the case de novo, using the following four factor test to determine if Haynes presented a prima facie showing of a discriminatory termination claim: (1) he was a member of a protected class; (2) he was satisfactorily performing his job at the time of the termination; (3) he was terminated from his employment; and (4) the prohibited conduct in which he engaged was comparable in seriousness to misconduct of other employees outside the protected class who received less severe discipline. After applying the four factor test and finding that a prima facie case had been established, the case was remanded for further review in light of these findings. Full Opinion
Tabitha Davidson