In Williams v. Masronardi Produce-USA, Inc., 2026 WL 2280615 (E.D.Mich. Aug. 7, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claims for gender/sex discrimination under Title VII of the Civil Rights Act of 1964. This case illustrates how courts apply the “McDonnell Douglas burden shifting framework” to discrimination claims.
From the decision:
To prove a prima facie case of gender discrimination, Williams must show: (1) she is a woman, (2) she suffered an adverse employment action, (3) she was qualified for the employment position, and (4) she was treated less favorably than a similarly situated male employee or was replaced by a male employee.
Mastronardi asserts that Williams’ prima facie case fails because she has not identified a similarly situated male comparator that was similar in all relevant aspects, engaged in the same conduct, and treated more favorably. Mastronardi points to the Court’s previous order granting summary judgment on Williams’ race discrimination claims based on the same failure to identify a comparator. Williams argues that comparator evidence “is not the exclusive means of proving discrimination” and “is not required in every case.” Instead, Williams asserts she is only required to present evidence which “permits a reasonable inference that an adverse action occurred because of plaintiff’s protected characteristics.” The Court disagrees with Williams.
As argued by Defendants, Jackson does not stand for the proposition that Plaintiff need not identify a similarly situated comparator. To the contrary, Jackson states the four elements required to establish a prima facie case of sex discrimination – including element (4) a similarly situated non-protected employee that was treated more favorably. The Sixth Circuit goes on to identify factors to consider in evaluating where a comparator is similarly situated for the purpose of establishing a prima facie case. Providing a similarly situated non-protected employee is a fundamental principal in discrimination cases.
Plaintiff’s attempts to identify evidence of gender-based discriminatory inferences (e.g., being required to continue interactions with Phillips despite reporting rejecting his advances, Jackson’s statements about rejection of advancements will result in retaliation and adverse treatment, and Phillips’ conduct as part of a broader sex-based pattern rather than an isolated personality conflict or neutral attendance issue) fail to foster a genuine issue of material fact as to her ability to establish a prima facie case of sex discrimination. Having failed to meet her burden of establishing a prima facie case, the Court need not advance in the McDonnell Douglas analysis.
Even when viewing these facts in the light most favorable to Williams, she still fails to establish the elements necessary to prove a prima facie case of gender/sex discrimination. Plaintiff has not identified a similarly situated male employee that was treated more favorably. To the extent that Williams argues that her comparator does not have to be similar in every conceivable respect and that courts must avoid applying an overly rigid comparator analysis, she still has failed to identify any comparator that would be similarly situated.
(Cleaned up; citations and quotation marks omitted.)
Accordingly, the court held that dismissal was warranted.