Background
Cameron J. Aikens sued his former employer, Herbalife International of America, Inc., alleging discrimination and retaliation under 42 U.S.C. § 1981. The U.S. District Court for the Middle District of North Carolina granted summary judgment to Herbalife.
On appeal, Aikens argued that the district court applied incorrect legal standards, improperly weighed the evidence, and wrongly struck evidence he had submitted.
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed. After reviewing the record, the court found no reversible error and concluded that Aikens had not established a genuine dispute of material fact.
The court said the result was the same whether Aikens’s claims were evaluated under the burden-shifting framework of McDonnell Douglas Corp. v. Green or under the text of § 1981. Judge Quattlebaum concurred separately to repeat his view that the McDonnell Douglas framework is counter-textual, more restrictive than the statute, more demanding than Federal Rule of Civil Procedure 56, and unnecessarily complex.
Key Takeaways
- Aikens failed to show a genuine dispute of material fact on his § 1981 discrimination and retaliation claims.
- The Fourth Circuit affirmed regardless of whether the claims were analyzed under McDonnell Douglas or directly under § 1981’s text.
- Judge Quattlebaum’s concurrence criticized the McDonnell Douglas framework but joined the per curiam decision in full.
Why It Matters
The decision confirms that challenges to the analytical framework will not prevent summary judgment when the record fails to present a genuine factual dispute under either approach. Because the opinion is unpublished, it is not binding precedent in the Fourth Circuit.