Mabra v. United Food & Commercial Workers Local Union No. 1996

HULL, Circuit Judge:

Ronald Mabra appeals the district court’s grant of summary judgment for Defendants- on his race-discrimination claim brought pursuant to 42 U.S.C. § 1981. On appeal, Mabra challenges the district court’s conclusion that the recent Title VII amendments limiting the impact of a mixed-motive defense do not apply to § 1981 claims. 1 We agree with the district court and thus affirm.

The district court reasoned that the mixed-motive amendments’ inapplicability to § 1981 claims was strongly suggested by this Court’s decision in Harris v. Shelby County Board of Education, 99 F.3d…