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Reginald Jonesv.Ups Group Freight

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.11-10416
DecidedJune 11, 2012
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsEmployment LawEmployment DiscriminationTitle VIISection 1983Civil ProcedureSummary JudgmentVacaturRemand
Case Summary

Reginald Jones, an African-American UPS Ground Freight driver, alleged that he endured a racially hostile work environment during his employment. He testified that a trainer referred to him as an Indian, that banana peels repeatedly appeared on his truck, that coworkers wore Confederate clothing, and that two yardmen confronted him at night after he complained. The district court granted UPS summary judgment, reasoning that the conduct was not racially motivated or objectively severe or pervasive. The Eleventh Circuit vacated and remanded. Applying the summary-judgment standard, the court held that a reasonable juror could infer that the banana incidents were racially motivated and could consider the events together rather than in isolation. The court emphasized the increasing frequency and seriousness of the conduct, the possible racial meaning of the Confederate imagery, the nighttime confrontation, and the object carried by one yardman. It also held that disputed evidence and credibility questions could not be resolved by the court at summary judgment. The decision did not establish that Jones would prevail; it held that his hostile-work-environment claim had to be tried.

Opinion

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