Arakji v. Microchip Technology, Inc.

Background

Mazen Arakji brought a hiring-discrimination case against Microchip Technology, Inc. His remaining claim alleged that Microchip discriminated against him based on religion, national origin, race, and disability when it declined to hire him for a Senior Engineer position.

The court previously granted Microchip’s motion for summary judgment. Summary judgment is a decision made without a trial when the court determines that the evidence does not present a legally sufficient dispute requiring a trial. Applying the burden-shifting framework used for discrimination claims, the court found disputes about whether Arakji had initially shown a basic discrimination case. But it also found that Microchip had provided legitimate, nondiscriminatory reasons for rejecting him and that Arakji had offered no evidence that those reasons were a pretext, or cover, for discrimination.

Arakji previously asked the court to undo the judgment, arguing that his interviewers could not have failed to notice his disability. The court denied that first request, explaining that the argument simply revisited an issue and concerned the initial discrimination showing, not the reasons and lack of pretext that supported summary judgment.

Second motion

Arakji’s second motion sought relief from the final judgment under Federal Rule of Civil Procedure 60. He argued that the summary-judgment decision was based on a mistake because Microchip’s explanation supposedly rested on the premise that its interviewers remembered interviewing him and remembered that he did not have a disability. Arakji characterized that premise as unbelievable and argued that the interviewers were untruthful.

Court’s reasoning

The court rejected that argument. It explained that its finding that Microchip had offered legitimate, nondiscriminatory reasons was based on substantial evidence concerning gaps in the languages required for the position, lack of experience with specific debugging tools such as JTAG, and Arakji’s failure to complete programming tasks during his in-person interviews. The court stated that none of that evidence concerned whether the interviewers noticed his disability.

The court also reiterated that the interviewers’ awareness of the disability related to Arakji’s initial discrimination showing, which was not the basis for the summary-judgment ruling. In addition, the court said that at the summary-judgment stage it does not assess witness credibility. It therefore found that Arakji had not identified a qualifying mistake under Rule 60.

Disposition

The court denied Arakji’s Second Motion for Relief from Final Judgment. Judge Beth Labson Freeman resolved the motion without oral argument.