Third Circuit Says Internal Transfer, BLM Statement Not Enough for Race Discrimination

Short summary

The Third Circuit affirmed dismissal of race discrimination and retaliation claims by a Black male employee who transferred teams after his manager opposed BLM and whose position was later eliminated. The court found no prima facie case of discrimination, rejected constructive demotion as a viable claim, and noted the same-actor inference favored the employer. The ruling underscores that legitimate reorganizations and performance concerns can defeat discrimination claims.

• •Third Circuit found employee failed to establish a prima facie case of race discrimination
• •Constructive demotion claim rejected for lack of intolerable working conditions
• •Same-actor inference and legitimate reorganization supported employer's summary judgment

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