In Brantley v. American Airlines, Inc., 2025 WL 1837472 (D.Nev. July 3, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race, color, or gender discrimination claims asserted under Title VII of the Civil Rights Act of 1964.
From the decision:
Brantley’s complaint also contains a Title VII discrimination claim on the theory that American discriminated against her because she is a light-skinned, African-American woman.38 She alleges that “documentation was supplied to corporate” that she believed would prove that she had been “singled out,” but that she was instead “made to be the aggressor” and discharged.39 American maintains that Brantley hasn’t plausibly pled race, color, or gender discrimination because she relies on conclusory allegations rather than factual allegations from which “an inference [of] race, color, or gender discrimination could be drawn.”40
To establish a prima facie case of discrimination in violation of Title VII, an employee must show that she (1) belongs to a class protected by Title VII; (2) performed her job satisfactorily; (3) suffered an adverse employment action; and (4) was treated differently than similarly situated employees who do not belong to the same protected class.41 Brantley’s complaint basically skips the second and fourth prongs. While she identifies herself as a member of protected class and alleges that she was terminated from her job, the complaint is silent on her job performance and whether American treated similarly situated coworkers outside of those protected class differently.42 Because Brantley’s allegations do not meet those essential elements, I dismiss her Title VII discrimination claims.
The court did, however, grant plaintiff leave to amend her complaint as to her Title VII claims.