Jimmy Haynes was vindicated on Tuesday when the Fourth Circuit Court of Appeals reversed a South Carolina federal district court judge’s determination that no juror could have found that his employer, Waste Connections Inc., unlawfully terminated his employment based on his race. The Fourth Circuit’s rulings cover North Carolina employment law issues for workers in Charlotte and throughout NC.
According to the submissions of the parties, Haynes (an African American male) had provided more than 8 years of dedicated service as a front-end load truck driver to Waste Connections and was locally renowned as one of the best at his position. Waste connections terminated Haynes’ employment after he missed a work shift due to a stomach virus even though he gave notice 45 minutes prior to his shift to a supervisor. The company argued at the district court level that the missed shift, causing a company truck to get stuck after missing a driveway, and poor work performance created legitimate reasons for his termination.
The record on appeal told a different story. Evidence submitted to the trial court revealed that Haynes had a recent positive performance review and a bonus shortly before his termination. Evidence also showed that Haynes’ white coworker Joe Hicks, with whom Haynes shared a supervisor and similar job responsibilities, was not subject to the same discipline. Hicks, was not terminated in spite of rule violations including yelling at supervisors and distracted driving.
In reversing the district court’s order dismissing Haynes’ case, the Fourth Circuit held that the evidence contained in the record on appeal was sufficient to raise the inference that Waste Connections terminated Haynes’ employment because of his race. It reasoned: “Hicks, who had more infractions and was less respectful to his superiors, may have engaged in more egregious conduct, yet received more favorable treatment.”
The court also rejected the district court’s holding that Haynes had not provided sufficient evidence that Waste Connections’ reasons for firing Haynes were pretext. The Court held that there was sufficient evidence where Waste Connections’ reasons for firing Haynes had “changed substantially” over time. Ironically, Waste Connections changed its alleged justification for terminating Haynes on appeal, arguing that it was due to his poor attitude even though it had not previously raised that reason at the trial court.
Haynes’ case serves as a bastion of hope for plaintiffs in the Fourth Circuit and will serve as favorable precedent in the fight against unlawful employment discrimination for North Carolina employees.