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Keywords

settlementplaintiffappealsummary judgmentdiscriminationwrongful termination
appealsummary judgmentdiscriminationwrongful termination

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Santillan v. USA Waste of Cal., Inc.

Facts

Gilberto Santillan worked for USA Waste for 32 years as a garbage truck driver and was known for his exemplary service. After a change in management, he faced disciplinary actions and was ultimately fired on December 5, 2011, allegedly for having four accidents. Following public outcry and a grievance filed by Santillan, a settlement agreement was reached in May 2012, which included his reinstatement contingent on passing certain tests. However, after Santillan complied with the requirements, he was fired again in July 2012 for not providing proof of his legal right to work.

Gilberto Santillan started working for USA Waste as a residential garbage truck driver in 1979. For 32 years, he serviced the community of Manhattan Beach, California. On December 5, 2011, USA Waste fired Santillan for the first time. USA Waste contends that it fired Santillan then because he had four accidents in a 12-month period for which Kobzoff disciplined Santillan using the procedures required by USA Waste's collective bargaining agreement.

Issue

Did the district court err in granting summary judgment in favor of USA Waste on Santillan's wrongful termination claims based on age discrimination and retaliation?

Did the district court err in granting summary judgment in favor of USA Waste on Santillan's wrongful termination claims based on age discrimination and retaliation?

Rule

To establish a prima facie case of age discrimination under California law, a plaintiff must show that they are a member of a protected class, performing competently, suffered an adverse employment action, and that there are circumstances suggesting discriminatory motive.

To state a prima facie age discrimination case under FEHA, Santillan must establish that: (1) he was a member of a protected class (i.e., 40 years of age or older); (2) he was performing competently in the position he held; (3) he suffered an adverse employment action, such as termination; and (4) 'some other circumstance that suggests discriminatory motive.'

Analysis

The Ninth Circuit found that Santillan met the criteria for establishing a prima facie case of age discrimination and retaliation. The court noted that the district court failed to consider the context of Santillan's termination and the evidence of a pattern of discrimination against older employees. The court emphasized that the employer did not provide sufficient evidence to justify the termination as legitimate and non-discriminatory.

The Ninth Circuit found that Santillan met the criteria for establishing a prima facie case of age discrimination and retaliation. The court noted that the district court failed to consider the context of Santillan's termination and the evidence of a pattern of discrimination against older employees. The court emphasized that the employer did not provide sufficient evidence to justify the termination as legitimate and non-discriminatory.

Conclusion

The Ninth Circuit reversed the district court's grant of summary judgment in favor of USA Waste on Santillan's wrongful termination claims and remanded the case for further proceedings, while affirming the denial of Santillan's request to amend his complaint.

The Ninth Circuit reversed the district court's grant of summary judgment in favor of USA Waste on Santillan's wrongful termination claims and remanded the case for further proceedings, while affirming the denial of Santillan's request to amend his complaint.

Who won?

Gilberto Santillan prevailed in the appeal because the court found that he established a prima facie case of age discrimination and retaliation, and the employer failed to provide a legitimate reason for his termination.

Gilberto Santillan prevailed in the appeal because the court found that he established a prima facie case of age discrimination and retaliation, and the employer failed to provide a legitimate reason for his termination.

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