The Sixth Circuit recently affirmed a summary judgment in favor of the City of Columbus (the “City”) on claims of race discrimination, hostile work environment, and retaliation brought by a number of its black employees. Arnold v. City of Columbus, 6th Cir. Nos. 11-3459, 33-3468, and 11-3815, 2013 WL 628447 (Feb. 20, 2013). The plaintiffs were able to establish prima facie race discrimination claims under Title VII of the Civil Rights Act of 1964 and the Ohio Civil Rights Act (the “OCRA”), Ohio Revised Code Ch. 4112, but they could not prove that the City’s proffered legitimate, nondiscriminatory reasons for its adverse employment actions were pretext.
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