DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
201192P.pdf 05/17/2021 Joseph Carter v. Atrium Hospitality
U.S. Court of Appeals Case No: 20-1192
U.S. District Court for the Southern District of Iowa - Des Moines
[PUBLISHED] [Kelly, Author, with Smith, Chief Judge, and Erickson, Circuit
Judge]
Civil case - Employment discrimination. Absent further instruction from
the Iowa Supreme Court, the court will apply the McDonnell Douglas
framework to claims under the Iowa Civil Rights Act; plaintiff's race
discrimination claim failed because the plaintiff had not presented
evidence that the context of his termination warranted an inference of
discrimination, and the district court did not err in granting summary
judgment for the employer; with respect to whether plaintiff made a prima
facie case of race discrimination on his failure-to-promote claim,
plaintiff failed to show the legitimate, non-discriminatory reasons the
employer provided for selecting other candidates were pretexts for race
discrimination; on plaintiff's hostile work environment, plaintiff failed
to show that the complained-about conduct was so abusive or severe that it
in effect altered the terms of his employment, and the district court did
not err in granting the employer summary judgment on the hostile work
environment claim.