Title VII Does Not Require Employer To Provide Reason for Firing Upon Termination

The U.S. Court of Appeals for the Eighth Circuit stated that, “Title VII does not impose a legal obligation to provide an employee an articulated basis for dismissal at the time of firing, and an employer is certainly not bound as a matter of law to whatever reasons might have been provided.”

In Rooney v. Rock-Tenn Converting Co., the employee was told that he was being terminated for poor interactions with co-workers. During litigation, the employer expanded the reasons to also include poor performance and customer complaints, and the employee argued that these later-added explanations were evidence of pretext for discrimination. The Eighth Circuit explained that an employer may later elaborate on its original explanation for an employment decision. Employers should note, however, that, as the Eighth Circuit pointed out, a “substantial shift” in explanation may be evidence of pretext.