Medina v. State of Oregon

A plaintiff makes a prima facie case when the evidence the plaintiff presents could cause a rational trier of fact to infer the claim is true. A trial court may not grant summary judgment to a defendant when the plaintiff has made a prima facie case.

Plaintiff appealed judgment dismissing his claims of race discrimination and race-based retaliation, arguing that because he presented a prima facie case for each claim, the trial court erred in granting the State summary judgment on all claims. Plaintiff contended that he had offered evidence that (1) he, as a Latino person, was not given promotion opportunities given to less-qualified white applicants; (2) he was disciplined with far more frequency than other employees; (3) that a vacation policy was implemented to target him; and (4) he was disciplined for actions for which white employees were not disciplined.

The Court of Appeals held that the evidence Plaintiff provided could cause a rational trier of fact to infer that discrimination did occur, and therefore that he presented a prima facie case of race discrimination and race-based retaliation. Since the Court held that Plaintiff presented a prima facie case for discrimination and race-based retaliation, the trial court erred in granting summary judgment to the State. Reversed and remanded on discrimination and race-based retaliation claims; affirmed regarding dismissal of a whistleblower claim.