the Civil Rights Act of 1964, §§ 2000e - 2000e-17 (1994). Norman L. Johnson has sued his former employer, Resources for Human Development (RHD), claiming that he was fired because of his race. RHD asserts that he was fired only for legitimate, nondiscriminatory reasons.
According to the Amended Complaint, Johnson is a licensed psychologist and was hired as Clinical Director for a residential program for troubled children in March, 1992. In June, 1993, Johnson was terminated by RHD and allegedly replaced by less experienced and less qualified white individuals. His Amended Complaint alleges a general racist environment at RHD resulting in disparate work assignments and access to facilities, as well as other disparate treatments of all African American employees, including himself. His Amended Complaint further alleges that he was fired from his position on account of his race.
According to RHD, Johnson was terminated because of his generally poor work product, uncooperative attitude, and refusals to follow instructions from supervisors. According to RHD, and corroborated by Johnson in notes he made at the time as well as at his deposition, the termination was precipitated by a series of events in late May, 1993. Johnson had been called to the program site by his supervisors because several children had skipped school and had generally misbehaved. Johnson's supervisors instructed him to hold additional group sessions with the children. He disagreed with this plan and, without authorization, instituted his own plan instead and left the premises for the day. Johnson admits that the following day he hung up on a supervisor during a telephone dispute.
SUMMARY JUDGMENT STANDARD
In considering a motion for summary judgment, a court must consider whether the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, show there is no genuine issue of material fact, and whether the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(c). The court must determine whether the evidence is such that a reasonable jury could return a verdict for the non-moving party. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 91 L. Ed. 2d 202, 106 S. Ct. 2505 (1986).
In making this determination, all of the facts must be viewed in the light most favorable to the non-moving party and all reasonable inferences must be drawn in favor of the non-moving party. Id. at 256. Once the moving party has met the initial burden of demonstrating the absence of a genuine issue of material fact, the non-moving party must establish the existence of each element of its case. J.F. Feeser, Inc. v. Serv-A-Portion, Inc., 909 F.2d 1524, 1531 (3d Cir. 1990), cert. denied, 499 U.S. 921, 111 S. Ct. 1313, 113 L. Ed. 2d 246 (1991) (citing Celotex Corp. v. Catrett, 477 U.S. 317, 323, 91 L. Ed. 2d 265, 106 S. Ct. 2548 (1986)).
LEGAL STANDARD FOR TITLE VII AND § 1981 CLAIMS
Johnson's claims arise under both Title VII and 42 U.S.C. § 1981. The legal elements of each of these causes of action are the same. O'Brien v. City of Philadelphia, 837 F. Supp. 692, 699 (E.D. Pa. 1993). For ease of discussion, we will do as the parties did and analyze Johnson's claims under Title VII law and caselaw. Title VII's § 2000e-2(a)(1) states:
It shall be an unlawful employment practice for an employer - to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin.