Williams v. PNC Bank, N.A.

Citations

• 202 N.E.3d 753
• 2022 Ohio 4287

Syllabus

Summary judgment Civ.R. 56 appellate review alternative argument Ohio Civil Rights Act R.C. 4112 discrimination race employment discrimination termination policy violations pretext. We reviewed a summary judgment granted in favor of the employer-defendants on a claim of race discrimination by a former employee. The trial court erred when it held that a plaintiff who was (1) African American, (2) qualified for his position as a Branch & Business Center Manager, (3) terminated from his job and (4) replaced by a Caucasian person had not established a prima facie case of race discrimination under the Ohio Civil Rights Act. The plaintiff urged us to remand the matter without considering the rest of the burden-shifting analysis relevant to his claim, but we concluded that the de novo standard of review allows us to consider the rest of the analysis. After doing so, we concluded that the defendants were entitled to summary judgment because they proffered a legitimate, non-discriminatory reason for the termination — namely, that an internal investigation concluded that the plaintiff had engaged in acts of dishonesty in violation of the employer's policies — and the plaintiff did not meet his burden to point to evidence showing a genuine issue for trial as to whether that stated reason was pretext. We, therefore, affirmed the summary judgment.