杰克逊诉哈卡比汽车公司案

Kathy Jackson, an African American woman, was a driver for Huckaby Automotive, doing business as Superior Automotive. In June 2021, a fellow driver made sexually suggestive comments to her. After Jackson reported the incident to supervisor Dianne Roberts, she was removed from the driver call list. Jackson sued her employer for race discrimination, hostile work environment, and retaliation under Title VII of the Civil Rights Act of 1964. The court allowed only her retaliation claim to proceed to discovery. Superior moved for summary judgment, arguing Jackson was not an employee but an independent contractor, and that she failed to prove retaliation.

The court granted Superior's motion for summary judgment and dismissed Jackson's Title VII retaliation claim with prejudice. The court found that while Jackson cast some doubt on Superior's version of events, she failed to show that the company's explanation—that she was removed for regularly turning down assignments—was false, or that retaliation was the real reason. Temporal proximity alone was insufficient to establish pretext.

Whether Superior Automotive removed Jackson from the driver call list in retaliation for her complaint about a coworker's sexually suggestive comments, or whether she was removed because she regularly refused to accept driving assignments. The central factual dispute concerned the number of calls and assignments Jackson received before and after her complaint.

The case illustrates the high bar plaintiffs face in proving retaliation under Title VII, particularly when proceeding pro se. It reinforces that mere temporal proximity between protected activity and adverse employment action is insufficient to defeat summary judgment without additional evidence of retaliatory intent. The decision also highlights the challenges employees classified as independent contractors face in bringing discrimination claims.