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.
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
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).
In addition, there is no evidence of disparate treatment between herself and similarly situated co-workers, there is no evidence of a cover-up, and there is no evidence that being consistently rude to customers in a consumer facing business to the extent that warranted multiple complaints would be an insufficient reason for termination. See Igwe v. Salvation Army, 790 F. App'x 28, 34-35 (6th Cir. 2019); see also McClain v. NorthWest Community Corrections Center Judicial Corrections Bd., 440 F.3d 320 (6th Cir. 2020). Therefore, this claim is dismissed.
So evidence that an employer took adverse action against an employee because of his accent "can constitute direct evidence of national origin discrimination" when that evidence shows "an unmistakable intent to discriminate upon national origin." Igwe v. Salvation Army, 790 F. App'x 28, 34 (6th Cir. 2019). See, e.g.
Comments regarding an individual's accent can constitute direct evidence of national origin discrimination. Igwe v. Salvation Army, No. 19-1082, 2019 WL 5424692, at *4 (6th Cir. Oct. 23, 2019). However, "[i]solated and ambiguous comments are insufficient to support a finding of direct discrimination."