Background
Galewood West Development, Inc., a Black-owned contractor, performed work on a property-development project for the City of Nixa, Missouri. Galewood alleged that the City failed to reimburse it for that work while paying similarly situated white contractors for comparable developments.
Galewood pursued race-discrimination claims against the City. The U.S. District Court for the Western District of Missouri entered summary judgment against Galewood, concluding that it had not shown a race-based difference in treatment between itself and similarly situated contractors.
The Court’s Holding
The Eighth Circuit affirmed the district court’s summary judgment. After reviewing the record and the parties’ appellate arguments, the panel adopted the district court’s reasoning.
The court therefore left intact the determination that Galewood failed to make any showing that the City treated it differently because of race when compared with similarly situated contractors. The unpublished per curiam opinion affirmed under Eighth Circuit Rule 47B.
Key Takeaways
- A contractor alleging race discrimination must show a race-based difference in treatment involving similarly situated contractors.
- Galewood did not make the required comparative showing concerning the City’s reimbursement decisions.
- The Eighth Circuit affirmed summary judgment in an unpublished per curiam opinion.
Why It Matters
The decision underscores the importance of comparator evidence in race-discrimination challenges to municipal contracting or reimbursement decisions. An allegation that other contractors were paid does not avoid summary judgment without a showing that comparable contractors received different treatment based on race.