Wagner v. Merit Distribution
The plaintiff, Charles Wagner, an African-American, sued Merit Distribution, Inc., James Austin, Sr., James Austin, Jr., and Austin Truck & Trailer Repair Center, LLC under 42 U.S.C. § 1981, alleging race discrimination, a racially hostile work environment, and retaliatory termination. Wagner also brought a state law claim for intentional infliction of emotional distress. The defendants filed motions for summary judgment, arguing against individual liability, the applicability of § 1981 to retaliation claims, and the merits of Wagner's discrimination claims. The court denied the defendants' motions for summary judgment on the race discrimination, hostile work environment, and intentional infliction of emotional distress claims, as well as the retaliation claim based on internal complaints, finding sufficient issues of material fact. However, the motion for summary judgment was granted for the retaliation claim specifically based on the filing of an EEOC charge, as the defendants had no knowledge of it at the time of termination.