Cummins, Inc. is entitled to summary judgment on a Black, male, customer quality engineer’s race discrimination and retaliation claims under Title VII of the Civil Rights Act when he wasn’t promoted after he filed a race discrimination complaint, and he was terminated allegedly due to a reduction in force, a federal district court in Tennessee ruled. He failed to establish a failure-to-promote claim because he didn’t suffer any adverse employment action, the court determined, as he never applied for or requested the interim quality leader position, which was a temporary role and not a promotional opportunity. No causal connection was ...
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