Cargo v. Kansas City Southern Railway Co.
United States District Court for the Western District of Louisiana
2012 WL 4596757 (Oct. 1, 2012)
Darren Stanley (plaintiff), a Black man, began working for Kansas City Southern Railway Company (KCS) (defendant) in 1998 and received two promotions. KCS terminated Stanley in 2002 after a company-wide email audit revealed that Stanley used his workplace computer to send over 46 inappropriate emails. Many of the emails were sexually explicit advances toward Stanley’s subordinate female employee, and some of them included inappropriate sexual content, such as the Simpsons children engaging in sexual acts. KCS had written policies governing computer use and prohibiting harassment. Stanley signed a written authorization confirming receipt of these policies. Stanley also demonstrated his awareness of the policy by repeatedly warning coworkers that they should not transmit personal messages through work computers. KCS had also warned Stanley about KCS’s computer use policy in 1998 after Stanley sent a sexually explicit email. Stanley sued KCS, raising race-based claims under Title VII of the Civil Rights Act of 1964. Stanley conceded that the 46 emails were inappropriate and lewd and did not dispute that the emails violated KCS’s computer-use and antiharassment policies but contested that other KCS employees were treated more favorably. KCS filed a summary-judgment motion, arguing that it terminated Stanley on legitimate, nondiscriminatory grounds.
Rule of Law
Holding and Reasoning (Hicks, J.)
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