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Discriminatory Animus Does Not Immunize Employee from Termination
Although a supervisor's discriminatory animus creates a multitude of issues for an employer, it does not, in and of itself, create liability where the supervisor is not the termination decision-maker. In Wray v. School District of Philadelphia, No. 14-5886, 2016 U.S. Dist. LEXIS 13319 (E.D. Pa. Feb. 4, 2016), the U.S. District Court for the Eastern District of Pennsylvania reaffirmed that a supervisor's discriminatory animus does not immunize an employee from termination.
Supervisor Bias
Odell Wray, an African-American man, worked as custodial assistant for the School District of Philadelphia. Wray was assigned to Motivation High School, where Yvonne Jones, an African-American woman, served as the principal. Jones, according to Wray, disapproved of Wray's interracial relationships, “bullied” Wray for dating one of the Caucasian teachers, and advised Wray that “jungle fever” was not allowed at the school. Jones also told others at the school that Wray was walking around with a “target on his back,” according to the opinion. On Nov. 16, 2011, after falsely accusing Wray of leaving work during his work shift, Jones admitted her mistake and told Wray that he could avoid these confrontations in the future if he “stuck to his own kind.”
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