Doug Becker v. Kikiktagruk Inupiat Corporatio

MEMORANDUM

Appellant Doug Becker appeals summary judgment in favor of Kikiktagruk Inupiat Corporation (“KIC”) on his claims for retaliation in violation of 42 U.S.C. § 1981 and for common law wrongful termination. The district court granted summary judgment to KIC on Becker’s retaliation claim because it determined that Becker had not presented evidence that he had engaged in a protected activity. The district court then granted summary judgment to KIC on Becker’s wrongful termination claim because it determined that KIC had not violated § 1981 and that Becker’s termination was not wrongful. We have jurisdiction pursuant to 28 U.S.C. § 1291 . Because Becker did present sufficient evidence that he engaged in a protected activity, we reverse and remand.

Retaliation claims pursuant to § 1981 are analyzed under Title VU’s burden-shifting framework. See, e.g., Metoyer v. Chassman, 504 F.3d 919, 930-31 (9th Cir.2007). Therefore, a prima facie case of § 1981 retaliation requires the plaintiff to show (1) that he “engaged in a protected activity,” (2) that he “suffered an adverse employment action,” and (3) that there was “a causal connection between the two.” Surrell v. Cal. Water…