02-06-2018
Title VII may require that employers have a non-discriminatory reason for terminating employees, but employers do not have to disclose those reasons at the time of termination.Aaron Rooney worked as an account executive for Rock-Tenn Converting Co. He had a mixed performance record, particularly with regard to his communication skills. When a new female supervisor was assigned to him, he continued to have problems with his primary account. When the problems did not improve after the customer complained, Rock-Tenn fired him. He was given a reason for the termination: his “difficulties with interacting with coworkers” and failure to support his account. Mr. Rooney believed that he was fired because he was Jewish and male. He claimed that the supervisors were “building a Jewish empire” and that he was replaced by a Jewish employee. He also stated that his female supervisor made comments about wanting more women in the office and did assign more women to accounts.
The Eighth Circuit Court of Appeals heard the case on appeal. The issue before it was whether Rock-Tenn should be allowed to expand the reasons for its termination of Mr. Rooney in litigation. The court of appeals held that: “Title VII does not impose a legal obligation to provide an employee an articulated basis for dismissal at the time of the firing, and an employer is certainly not bound as a matter of law to whatever reasons might have been provided.” Significant differences in the articulated reasons termination could reflect pretext, but elaborating on those reasons would not. Rock-Tenn had provided more examples of Mr. Rooney’s poor performance. As Mr. Rooney failed to show that these reasons were pretextual, summary judgment against him was appropriate.