This the direct evidence standard does not permit. See, e.g., Igwe v. Salvation Army, 790 Fed.Appx. 28, 34 (6th Cir. 2019) (finding that the employer's comments did not relate to the issues that led to the adverse employment action). Therefore, Morella's alleged comment does not provide sufficient direct evidence of racial discrimination.
The Sixth Circuit informs us that “[d]irect evidence of discrimination does not require a factfinder to draw any inferences in order to conclude that the challenged employment action was motivated, at least in part, by unlawful discrimination.” Igwe v. Salvation Army, 790 Fed.Appx. 28, 34 (6th Cir. 2019) (emphasis added). In this context, Plaintiff points the Court to an internal communication from Norfolk Southern regarding her termination.
“Direct evidence of discrimination does not require a factfinder to draw any inferences in order to conclude that the challenged employment action was motivated, at least in part, by unlawful discrimination.” Igwe v. Salvation Army, 790 Fed.Appx. 28, 34 (6th Cir. 2019) (citing Johnson v. Kroger Co., 319 F.3d 858, 865 (6th Cir. 2003)).
Additionally, the Sixth Circuit has directed that, when selecting a candidate for a management position, “an employer has even greater flexibility with its choice.” Taylor, 2024 WL 3217590, at *6; see also Igwe v. Salvation Army, 790 Fed.Appx. 28, 35 (6th Cir. 2019) (“As we have long held, so long as its reasons are not discriminatory, an employer is free to choose among qualified candidates when making hiring decisions.”) (cleaned up).
Race, national origin, color, and religious discrimination are, respectively, separate types of Title VII claims. Wakefield v. Child.'s Hosp., No. C2-06-1034, 2008 WL 3833798, at *6 (S.D. Ohio Aug. 13, 2008); see also Ang v. Procter & Gamble Co., 932 F.2d 540, 546 (6th Cir. 1991), abrogated on other grounds by Igwe v. Salvation Army, 790 Fed.Appx. 28, 36 (6th Cir. 2019). Plaintiffs claim that they were discriminated against based only on their race as African Americans
“[A] reason cannot be a pretext for discrimination unless it is shown both that the reason was false, and that discrimination was the real reason.” Igwe v. Salvation Army, 790 Fed.Appx. 28, 35 (6th Cir. 2019) (quoting Seeger v. Cincinnati Bell Tel. Co., 681 F.3d 274, 285 (6th Cir. 2012)).
Race, national origin, color, and religious discrimination are, respectively, separate types of Title VII claims. Wakefield v. Child.'s Hosp., No. C2-06-1034, 2008 WL 3833798, at *6 (S.D. Ohio Aug. 13, 2008); see also Ang v. Procter & Gamble Co., 932 F.2d 540, 546 (6th Cir. 1991), abrogated on other grounds by Igwe v. Salvation Army, 790 Fed.Appx. 28, 36 (6th Cir. 2019). Plaintiffs must show direct or sufficient indirect evidence specific as to each type of claim in order to survive summary judgment as to claims of that type.
) Thus, Almasri must show that this proffered reason “(1) had no basis in fact, (2) was not the actual reason for the [adverse action], or (3) was insufficient to explain it.” Igwe v. Salvation Army, 790 Fed.Appx. 28, 34 (6th Cir. 2019) (citing Imwalle v. Reliance Med. Prods. Inc., 515 F.3d 531, 545 (6th Cir. 2008)).
Race, national origin, color, and religious discrimination are, respectively, separate types of Title VII claims. Wakefield v. Child.'s Hosp., No. C2-06-1034, 2008 WL 3833798, at *6 (S.D. Ohio Aug. 13, 2008); see also Ang v. Procter & Gamble Co., 932 F.2d 540, 546 (6th Cir. 1991), abrogated on other grounds by Igwe v. Salvation Army, 790 Fed.Appx. 28, 36 (6th Cir. 2019). Plaintiffs must show direct or sufficient indirect evidence specific as to each type of claim in order to survive summary judgment as to claims of that type.
"Direct evidence of discrimination does not require a factfinder to draw any inferences in order to conclude that the challenged employment action was motivated, at least in part, by unlawful discrimination." Igwe v. Salvation Army, 790 Fed.Appx. 28, 34 (6th Cir. 2019).