Hancy Joseph, an African-American man, sued his former employer for race and national origin discrimination. He had been employed by Owens and Minor Distribution, Inc. (O & M) and was promoted to senior project analyst approximately a year after his hire. Once in that position, Mr. Joseph was required to regularly interact with clients. O & M had given him good performance evaluations for certain aspects of his performance but removed him from two or more clients because of interpersonal disputes.
The culminating situation occurred when Mr. Joseph was asked to leave a client meeting. He had been questioning the client’s request, which caused an argument between him and the O & M manager. Mr. Joseph refused to leave the premises when asked. The client apparently dismayed by the situation asked not to work with Mr. Joseph. Mr. Joseph complained that the manager had asked him to leave because of his race. O & M conducted an investigation into his allegations but could not find a racial motivation for the manager’s actions. Mr. Joseph remained on the job. However, problems continued to arise between him and the client, causing O & M to ultimately remove him from the project. The company then fired him for a history of problems with interpersonal interactions.
Mr. Joseph’s suit alleged that the company’s treatment of him was based on race and that he was terminated in retaliation for his race based complaints. The Second Circuit Court of Appeals upheld the lower court’s dismissal of Mr. Joseph’s case. O & M had presented legitimate non-discriminatory reasons for firing Mr. Joseph and had evidence to back it up. It had engaged in several attempts to help Mr. Joseph’s interpersonal skills as well as conducting an internal investigation. Other than his belief, Mr. Joseph had no evidence of racial animus.