No Retaliation Where Employer Mistakenly Believed Employee Lied
The U.S. Court of Appeals found that an employee’s claim for retaliation under Title VII failed where her termination was based on the employer’s mistaken belief that she had lied in reporting harassment by a manager.
In Villa v. Cavamezze Grill, LLC, the employee reported that a subordinate had told her that the restaurant’s general manager had offered the subordinate a raise in exchange for sex, and that she suspected another subordinate had left for the same reason. During the company’s investigation, the subordinate denied making such a statement to the employee, and the second subordinate denied that the GM had made such an offer. The employer concluded that the employee had lied, and terminated her. She sued for retaliation, and during the course of the lawsuit, the first subordinate admitted that she had, in fact, told the employee that the GM had harassed her, although she further admitted the claimed harassment was a lie.
The employee argued that her termination was illegal retaliation because her complaint was made in good faith. The trial court rejected her argument, however, and the 4th Circuit affirmed the trial court’s ruling. The 4th Circuit emphasized that the employer’s motivation was the focus of a retaliation claim. Here, the employer’s reason for the termination was its good faith belief that the employee had lied – even if the employer was mistaken in its belief – and not a desire to retaliate against the employee for reporting harassment.
