Angela Roberson-King v. State of LA Workforce Cmsn
Opinion
Angela Roberson-King worked as a rehabilitation counselor at Louisiana Rehabilitation Services (LRS), a division of Louisiana's Office of Workforce Development. In 2014, she applied to become a district supervisor at LRS. She interviewed for the position but did not receive it. Roberson-King then sued LRS in federal district court, alleging that she was denied a promotion because of her race in violation of Title VII of the Civil Rights Act and Louisiana tort law. The district court dismissed the state law claims under Federal Rule of Civil Procedure 12(b)(6) and granted LRS summary judgment on the Title VII claim. We affirm.
I.
Roberson-King first argues that she stated a valid claim under Louisiana Civil Code article 2315 because LRS
*380
breached its statutory duties under Title VII.
1
Article 2315 provides that "[e]very act whatever of man that causes damage to another obliges him by whose fault it happened to repair it." La. Civ. Code art. 2315(A). The district court dismissed this claim, holding that a state law suit for racial discrimination in employment must be brought under the Louisiana Employment Discrimination Law (LEDL), not Article 2315. We review
de novo
a district court's dismissal for failure to state a claim.
Taylor v. City of Shreveport
,
Under Louisiana law, when two statutes conflict, the "statute specifically directed to the matter at issue must prevail as an exception to the statute more general in character."
Kennedy v. Kennedy
,
Article 2315 contains no similar procedural requirements or limitations on damages.
See
Gluck v. Casino Am., Inc.
,
II.
We review
de novo
the district court's grant of summary judgment on Roberson-King's Title VII claim.
Moss v. BMC Software, Inc.
,
A Title VII employment discrimination case based on circumstantial evidence is evaluated under the
McDonnell Douglas
burden-shifting framework.
See
*381
McDonnell Douglas Corp. v. Green
,
It is undisputed that Roberson-King has established a prima facie case of employment discrimination. She is African-American and was qualified for the district supervisor position. Roberson-King was not offered the position. The employee who received the promotion, Mara Lott Patten, is white. But LRS contends that it promoted Patten because she was the more competitive candidate for the position. Specifically, LRS points to Patten's status as a Certified Rehabilitation Counselor (CRC), a credential Roberson-King did not have. This satisfies LRS's burden to provide a legitimate, non-discriminatory basis for its decision.
See
Reeves v. Sanderson Plumbing Prods., Inc.
,
The burden therefore shifts back to Roberson-King to show that LRS's asserted justification is pretextual. A plaintiff can demonstrate pretext through evidence that she was " 'clearly better qualified' (as opposed to merely better or as qualified)" than the chosen employee.
EEOC v. La. Office of Cmty. Servs.
,
The record indicates that Roberson-King and Patten each exceeded the minimum qualifications for the district supervisor position, and neither candidate was clearly better qualified. Both held master's degrees, were Master Counselors at LRS, and had some supervisory experience. Roberson-King had a longer tenure with LRS and the Louisiana state government, *382 but Patten achieved the rank of Master Counselor more quickly after joining the agency. Roberson-King was selected to attend a leadership academy and had an extra 15 hours of graduate credit, but she lacked the CRC certification that Patten held. Roberson-King supervised about ten individuals as a first sergeant in the Air Force Reserves. Patten had supervised only one employee, but her supervisory experience was within LRS. Roberson-King had a somewhat better record of meeting her production quotas, but both candidates fell short of their quotas twice in the period since Patten joined LRS.
Any difference in qualifications between the two candidates does not create a genuine issue of fact that Roberson-King was
clearly
better qualified for the district supervisor position. "[E]mployers are generally free to weigh the qualifications of prospective employees, so long as they are not motivated by race."
Martinez v. Tex. Workforce Comm'n-Civil Rights Div.
,
Roberson-King also emphasizes that the appointing authority at LRS, Bryan Moore, attempted to rescind Patten's promotion after Roberson-King filed a grievance alleging racial discrimination. But this decision, by itself, does not constitute evidence of pretext. Moore testified that he attempted to stop the process because he takes allegations of racial discrimination very seriously and wanted to ensure that everything was done properly. There is no evidence in the record that Moore uncovered any discrimination in the promotion decision. Accordingly, Roberson-King has failed to raise a genuine issue of fact as to pretext. AFFIRMED.
Roberson-King has abandoned her claim for intentional infliction of emotional distress.
Roberson-King instead relies on dicta from our opinion in
Guillory v. St. Landry Par. Police Jury
,
Reference
- Full Case Name
- Angela ROBERSON-KING, Plaintiff-Appellant v. State of LOUISIANA WORKFORCE COMMISSION, OFFICE OF WORKFORCE DEVELOPMENT, Louisiana Rehabilitation Services, Defendant-Appellee
- Cited By
- 52 cases
- Status
- Published