Williams v. Tucson Unified School District

MEMORANDUM **

In April 2001, Tucson Unified School District (Tucson) did not hire David Williams, an African-American male, for a supervisory position within its transportation department. He brought suit under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., alleging that Tucson’s decision was in retaliation for a complaint he made to it about the lack of African-Americans in supervisory roles. The district court granted defendants-appellees’ motion for summary judgment.

Williams makes two arguments here: (1) the district court erred in precluding his retaliation claim under § 1981 and (2) the court improperly granted defendants’ summary judgment motion on his Title VII retaliation claim. The district court, however, did not err because Williams failed to carry his prima facie burden to show causation, which is required for both of his retaliation claims. We therefore affirm the judgment of the district court.

I.

Retaliation claims under Title VII and § 1981 share identical legal standards. 1 See Manatt v. Bank of Am., N.A., 339 F.3d 792, 801 (9th Cir.2003).

To establish a prima facie case of retaliation, a plaintiff must…