8th Cir: Demotion 1 year after protected activity wasn't retaliation - HR Dive
Dive Brief:
Dive Brief:
- An employee's demotion wasn't retaliation because, among other factors, it took place almost a year after the employee engaged in protected conduct, the 8th U.S. Circuit Court of Appeals ruled (Williams v. United Parcel Service, Inc., No. 19-1004 (9th Cir., June 29, 2020)).
- Cedric Williams worked for UPS as a labor manager, representing the company in grievance proceedings. After alleged performance deficiencies, he was placed on a performance improvement plan and eventually demoted; he sued, claiming race discrimination and retaliation. He argued that his previous participation in a race discrimination grievance proceeding was the real reason for his demotion, noting that the ultimate decision makers — an HR director and district president — knew about that protected activity.
