Bonazza v. MUFG Bank, Ltd.
- Joseph Spero
- 3:23-cv-01161
- U.S. District Court · Northern District of California
- 2
In Bonazza v. MUFG Bank, Judge Spero denied Bonazza’s two summary-judgment motions because he provided no supporting legal argument or evidence for his Title VII claim.
Michael Alan Bonazza, who was proceeding without a lawyer, and MUFG Bank, Ltd.; the court denied Bonazza’s two remaining summary-judgment motions.
What happened
In Bonazza v. MUFG Bank, Ltd., Michael Alan Bonazza alleged that MUFG Bank failed to extend his employment contract because of his gender and race. The court treated the allegation as a discrimination claim under Title VII of the Civil Rights Act of 1964.
Bonazza filed two similar motions asking for summary judgment and monetary damages. He did not provide a supporting legal brief or evidence showing that there was no important factual dispute or that he was entitled to judgment under the law.
Judge Joseph C. Spero denied both remaining motions. The court had previously denied a third, identical motion as moot, meaning it did not need to decide that motion because a later identical motion was pending.
The detailed version
- Bonazza v. MUFG Bank, Ltd. · No. 3:23-cv-01161
- Joseph Spero
- May 29, 2024
Background
Michael Alan Bonazza alleged that MUFG Bank, Ltd. failed to extend his employment contract because of his gender and race. The court had construed his complaint as asserting a discrimination claim under Title VII of the Civil Rights Act of 1964. Bonazza was proceeding without a lawyer.
Bonazza filed three summary-judgment motions. The court had already denied docket number 108 as moot because it was identical to docket number 109. The order addressed docket numbers 109 and 111.
Court’s Analysis
Summary judgment is appropriate when the moving party shows that no genuine dispute exists about any material fact and that the party is entitled to judgment as a matter of law. For his discrimination claim, Bonazza needed to present direct or circumstantial evidence that discriminatory intent motivated MUFG Bank, or establish an inference of discrimination under the burden-shifting framework recognized in McDonnell Douglas Corp. v. Green.
Docket number 109 was a one-page motion seeking $6,918,000 for alleged lost wages, incremental discretionary performance compensation, distress, and back pay. Docket number 111 was virtually the same, with slightly increased dollar amounts. Neither motion included a supporting legal brief or evidence. The court concluded that Bonazza had not addressed his specific discrimination claim or provided evidence and argument showing that he was entitled to summary judgment based on undisputed facts.
Ruling
The court denied the two remaining summary-judgment motions. The order did not grant summary judgment to either party or decide that MUFG Bank was liable for discrimination.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.