A recent case from the Fourth Circuit explains that employee “fit” can be a valid basis for termination, but the employer must be able to show legitimate reasons for the termination.
In Lashley v. Spartanburg Methodist College, a criminal justice professor at Spartanburg Methodist College (SMC) alleged that her termination and contract nonrenewal were illegal both under state and federal law. After her claims were dismissed on summary judgment by the district court, Lashley appealed, alleging that her termination was due to retaliation and discrimination, and that her former employer was simply using “fit” as a guise.
On appeal, SMC needed to provide evidence of nondiscriminatory and nonretaliatory reasons for why Lashley was not a good fit, leading to the rational decision not to renew her contract. SMC provided reports of Lashley’s unprofessional and threatening behavior towards students and other faculty members. The evidence provided included multiple reports that the President of SMC received regarding Lashley’s continuous “inappropriate and threatening behavior.”
The reports included allegations that Lashley was unorganized and unprepared for classes, she was often the center of conflicts with students and faculty, she lacked collegiality with supervisors, she played favorites with students, and she avoided issue resolution opportunities with supervisors. The Court found that cumulatively, these complaints created a legitimate basis not to renew Lashley’s contract.
Another one of the reports included allegations that Lashley threatened to blow up the school and spoke about death threats to those who crossed her. The President of SMC found that Lashley was potentially violent and a threat to campus safety. This created a legitimate reason to not only choose not to renew her contract but also to terminate her immediately.
After SMC provided its evidence that Lashley was terminated for not being a good fit at the college, Lashley was then allowed to rebut the evidence with documentation and information of her own. However, Lashley could not overcome the evidence produced by SMC. She failed to provide evidence to show a retaliatory or discriminatory motive beyond speculation that SMC’s “fit” justification was not the true reason for terminating her. Since SMC was able to show valid nonretaliatory reasons for Lashley’s termination and contract nonrenewal, the district court’s dismissal of the claims was affirmed.
In claims against an employer for wrongful termination, retaliation, or discrimination as the basis for terminating an employee, the employer must provide evidence to show legitimate, nondiscriminatory reasons for the termination or adverse actions taken against the employee. The employee then gets one final chance to show that the employer’s reasons were actually a pretext for unlawful retaliation or discrimination.
Employers may terminate employees for not being a good fit for the job or the company’s mission, but there must be evidence that the reasons related to fit are rational and legitimate. An employer may not fire an employee for improper or discriminatory reasons and use “fit” as the cover reason for termination. If an employer has more specific reasons to terminate an employee, it is best practice to specify the reasons and only use “fit” sparingly and truthfully.