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Dismissal of AutoZoners claims adjuster’s bias charges upheld


A federal appeals court has upheld dismissal of age, race and gender discrimination and retaliation charges filed by a former claims adjuster in AutoZoners L.L.C.’s risk management department.

As a claims coordinator in the risk management department of AutoZoners, a unit of Memphis, Tennessee-based AutoZone Stores Inc., Linda King, an African-American woman over the age of 40, was responsible for preparing a weekly corporate accident review report, among other duties, according to Wednesday’s ruling by the 6th U.S. Circuit Court of Appeals in Cincinnati.

In January 2013, AutoZoners hired a new risk management director, who later restructured the department with an increased focus on analytics, automation and efficiency, according to the ruling in Linda King v. AutoZoners L.L.C.

The restructuring eliminated the claims coordinator position, which resulted in Ms. King’s termination in September 2013, but also created a new associate risk analyst position, according to the ruling.

Following Ms. King’s termination, her supervisor temporarily assumed responsibility for the corporate report. AutoZoners subsequently hired as the new associate risk analyst a man who took over the report’s preparation. He was able to complete the report in about two hours “signficiantly less time than King required for the task,” said the ruling. Eventually, he also became responsible for preparing about 30 other reports for the company through data queries and analysis, said the ruling.

Ms. King filed suit for age discrimination in violation of the Age Discrimination in Employment Act, and race and gender discrimination as well as retaliation in violation of Title VII of the Civil Rights Act of 1964.

The U.S. District Court in Jackson, Tennessee, granted AutoZoners summary judgment on all the claims, which was upheld on appeal by a unanimous three-judge appeals court panel.

The District Court held that Ms. King “abandoned her retaliation claim at summary judgment, failed to exhaust her administrative remedies for her gender discrimination claim, and could not make out her prima facie case on her race and age discrimination claims,” said the appeals court ruling.

The lower court “found she produced no evidence demonstrating that she was replaced by a nonprotected employee, because her supervisor took over most of her tasks and (the associate risk analyst) took over the remaining tasks.

“It also found that she failed to demonstrate that a similarly situated, nonprotected emplyer received more favorable treatment than she did,” said the panel, in finding the lower court did not err and upholding its ruling.

In June, in a case involving AutoZone Inc., a federal appeals court upheld dismissal of a case filed by the U.S. Equal Employment Opportunity Commission in which the agency contended that a black employee who was laterally transferred from a store with a largely Hispanic clientele had been discriminated against.