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Barnett v. Department of Veterans Affairs,
153 F.3d 338 (6th Cir. (Ky.) Aug. 28, 1998)
The Plaintiff, Dr. Barnett, worked as a counseling psychologist
in the United States Department of Veterans Affairs. Each year she was evaluated
under a system which kept track of her procedural, judgmental, and substantive
errors. All employees were allowed to make a certain number of each type of error
before facing disciplinary action. Mullins, Barnett’s supervisor, sent the
Plaintiff a notice that she had exceeded the yearly allowable number of errors
and that she was to be placed on a sixty-day probationary period. Barnett made
several errors during that period and, as a result, was terminated and replaced
by a younger male. Barnett sued in federal district court alleging age discrimination.
The district court held that the reasons for Dr. Barnett’s discharge were
not fabricated or pretextual and, therefore, she was not entitled to recover.
Dr. Barnett appealed the case.
The Sixth Circuit began by laying out the four prongs
of the McDonnell Douglas test, under which an ADEA case is to be analyzed,
and by noting that Barnett successfully carried her burden in making out a prima
facie case of age discrimination. Specifically, she was age 51 when she was fired
and replaced by a significantly younger male. The court did not address whether
she was qualified for the position. The court then turned its attention to whether
the proffered reasons for the termination were pretexts for discrimination.
The district court found that Barnett failed to demonstrate
that the reasons for her termination as provided by the employer were pretextual
under St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993). Under
St. Mary’s, a plaintiff seeking recovery bears the burden of proving
a discriminatory animus, notwithstanding the failure of the defendant’s proffer
of legitimate nondiscriminatory reasons for the adverse employment action. The
Court of Appeals reviewed the testimony of the witnesses and ultimately found
that there was no reason to place more credibility on Barnett’s statements
than those of her supervisors. That being the case, the court deferred to the
trial court’s holding that discriminatory treatment did not cause Barnett’s
termination. The Sixth Circuit, therefore, upheld the decision of the lower court.
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