Rose-Colored Glasses Don't Save Plaintiff's Discrimination Claim

Establishing that an employer's stated legitimate reason for an adverse action is a "pretext" for discrimination requires more than a former employee's word for it.

So held the United States Court of Appeals for the First Circuit when affirming the Massachusetts district court's summary judgment ruling in Boykin v. Genzyme Therapeutic Products, LP [Genzyme] and Beausoleil.

First, let's examine the facts...

Boykin, an African-American man, worked for Genzyme investigating deviations from the company's standard manufacturing processes.

After a few years, his direct supervisor and the supervisor's superior, Beausoleil, (separately) discussed the pace of Boykin's work with him. Then, the head of finance at the site publicly criticized Boykin when Genzyme failed an external audit. Boykin felt this was race-based discrimination, complained to HR, and the finance guy apologized.