Documentation And Communication FTW! (Well, Good Enough.)

After completing a 90-day orientation program for newly licensed nurses, a woman was denied a full-time position as a Registered Nurse (RN) at a hospital and, instead, transferred into a lower-paying position at another facility that the same employer operated.

The woman — we'll call her "Plaintiff" as we usually do here — alleged race discrimination under Title VII of the Civil Rights Act of 1964.

A plaintiff asserting a Title VII claim for race discrimination must present a convincing mosaic to the factfinder that race motivated the adverse employment action — in this case, the denial of the full-time RN position.

Defendant produced all sorts of documented progress forms demonstrating that Plaintiff underperformed during the orientation period. Although Plaintiff disagreed with Defendant's assessment, that was not enough to establish that their reasons for not moving her into a full-time RN position were a pretext for race discrimination.