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Same actor inference entitles employer to summary judgment.

Coghlan v. American Seafoods Co. LLC, 413 F.3d 1090 (9th Cir. July 7, 2005) - This is a Title VII national origin discrimination action alleging wrongful demotion. Because the person who demoted James Coghlan is the same person who had previously taken favorable employment actions on Coghlan's behalf, the Court addresses the same actor inference. The Court explains that the same actor inference creates a strong inference that there was no discriminatory action. The Court reviews Coghlan's evidence of pretext and holds that that evidence is not sufficient to rebut the same actor inference. Therefore, the employer is entitled to summary judgment as a matter of law. Click here to see actual case.