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Court Finds Temporal Proximity Alone Is Not Sufficient to Support ERISA Discrimination Claim
Seyfarth Shaw LLP June 2, 2016 "A recent decision district court ruling affirms that in a benefit discrimination claim, just as in a typical claim of employment discrimination, to survive summary judgment a plaintiff must demonstrate that a defendant's given lawful reason for taking an adverse action was pretext. Temporal proximity between an adverse action and an enrollment in an ERISA plan (without more), is insufficient to overcome an employer's legitimate, nondiscriminatory reason for the termination." [Francis v. South Central Houston Action Council Inc., No. 14-1277 (S.D. Tex. Apr. 25, 2016)] |
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