Angela Pulliam v. United Airlines

MEMORANDUM

Angela Pulliam appeals from the district court’s grant of summary judgment in favor of United Airlines on Pulliam’s claims for race and color discrimination and retaliation pursuant to Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 1981 (“ § 1981”), and Nevada Revised Statutes Chapter 613. Reviewing de novo, see Fin. Mgmt. Advisors, LLC v. Am. Int’l Specialty Lines Ins. Co., 506 F.3d 922, 925 (9th Cir.2007), we affirm the judgment of the district court.

Pulliam, who self-identifies as black African-American, alleges two separate incidents of race discrimination: (i) the Giusti incident, in which Pulliam was issued a “Letter of Counseling” after supervisor Patricia Giusti reported that Pulliam could not be found in her assigned work area, and (ii) the Hill incident, in which supervisor LaToyia Hill terminated Pulliam following complaints that Pulliam engaged in a confrontation with two United passengers and that Pulliam habitually left work early. Pulliam argues that the district court erred in its analysis under the McDonnell Douglas burden-shifting framework. McDonnell Douglas Corp. v. Green, 411 U.S. 792 , 93 S.Ct. 1817 , 36 L.Ed.2d 668…