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Roberson-King v. State of Louisiana Workforce Commission No. 17-30899

http://www.ca5.uscourts.gov/opinions/pub/17/17-30899-CV0.pdf

Before STEWART, Chief Judge, WIENER, and HIGGINSON, Circuit Judges.

AFFIRMED. (September 17, 2018).

Angela Roberson-King was employed 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 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. Roberson-King appealed. The Fifth Circuit affirms the District Court’s judgment. It was undisputed that Roberson-King established a prima facie case of employment discrimination. However, LRS asserted a justification that was not pretextual. There was no evidence in the record of any discrimination in the promotion decision, and the Court reasons that any difference in qualifications between the two candidates did not create a genuine issue of fact that Roberson-King was clearly better qualified for the district supervisor position. Finally, the Court explains that the choice to value the other candidate’s credentials over Roberson-King’s strengths was within the realm of reasonable business judgments.

On Appeal from the United States District Court for the Western District of Louisiana (S. Maurice Hicks, Jr.).
Attorney for Appellant – Scott Damon Wilson, Baton Rouge, LA
Attorney for Appellee – Danielle N. Brown, Shreveport, LA

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