Ron Brown, an African American employee at Life University, a private chiropractic school in Georgia, alleged that he was fired in retaliation for complaining about racial discrimination and that Life University’s proffered reasons for his dismissal—timekeeping violations and inappropriate conduct toward a coworker—were not worthy of belief. One of the key events underpinning his claims involved Brown reporting that a temporary employee, Adamari Obregon, had falsified her timesheets. Obregon was terminated shortly thereafter. Brown also alleged that Obregon’s supervisor, Javier Cabanas, who was in a romantic relationship with Obregon, then retaliated against Brown by accusing Brown of falsifying his own timesheet. Cabanas’s accusation came just days after Obregon’s termination and ultimately led to Brown’s firing.
Brown filed suit, claiming that retaliation and race discrimination under Title VII and 42 U.S.C. Section 1981. The University filed a motion for summary judgment.
In their motion, Life University argued that Brown was terminated because he falsely claimed to have worked on a day he had called out sick and for allegedly berating another employee. The University claimed that its internal investigation, conducted by supervisors Colin Hilley and Lisa Ward, independently verified the timekeeping violation. However, the Court found that the investigation was minimal and failed to include basic follow-up, such as questioning Brown about whether anyone else had access to his timekeeping credentials. This was particularly noteworthy, because evidence in the record showed that someone else could have logged into the timekeeping system using Brown’s credentials, undermining the University’s assertion that it had conclusively verified he had falsified his timesheet. Moreover, the record showed that 24 minutes after Hilley and Ward spoke with Brown about the accusations, Hilley and Ward read from an already typewritten letter that said they were firing him, “effective immediately.”
The Court further emphasized that Brown, during the termination meeting, explicitly told Ward and Hilley that Cabanas had motive to retaliate against him, that Cabanas had access to his timekeeping login credentials, and that he had documented his sick day with his supervisor. The Court concluded that a jury could find that Ward failed to conduct a good-faith investigation and instead accepted a possibly retaliatory accusation at face value. Ward’s refusal to investigate further, even after hearing Brown’s explanation, raised a triable issue of fact regarding whether the timekeeping violation was a pretext for unlawful retaliation.
In addition to the timekeeping issue, the University asserted that Brown was also fired for verbally abusing another employee named Chris. Hilley claimed to have personally witnessed Brown yelling and using profanity, which allegedly caused Chris to leave work in tears and ultimately resign. Brown, however, denied raising his voice or using profanity and claimed Chris did not cry or quit because of the interaction. According to Brown, Chris completed his shift, returned to work days later, and ultimately left the position for unrelated reasons. The Court determined that the conflicting accounts raised a credibility issue for a jury to resolve. If a jury found Brown’s version credible, it could conclude that Hilley fabricated or exaggerated the incident to justify Brown’s termination.
On the race discrimination claim, the Court found that a jury could reasonably infer that Ward and Hilley served as mere “rubber stamps” for Cabanas’s report and failed to conduct an adequate or independent investigation. This, the Court reasoned, could support a finding that Cabanas’s alleged racial animus was the real cause of Brown’s termination. The Court rejected the University’s objection that the speed of the investigation was not evidence of insufficiency, noting that the investigation’s timing, cursory nature, and failure to pursue key information were all potentially relevant to pretext.
The Court concluded that Brown had produced sufficient evidence of retaliation and discrimination to survive summary judgment. It ordered the parties to mediation and stayed the proceedings pending the outcome.
Brown v. Life University, Inc., No. 1:23-cv-2487-MLB (N.D. Ga. Mar. 31, 2025).
Note: This decision underscores the importance of conducting thorough and impartial investigations. Here, the court found that the University’s failure to ask basic questions or consider the employee’s explanation sufficient to support a claim that the employer’s stated reasons for termination might be pretextual for discrimination.