Labor & Employment Law Daily Wrap Up, RETALIATION—S.D. Miss.: Fired Black female detective advances retaliation, business interference claims, (Oct 14, 2025)

By Tulay Turan, J.D.

The city submitted no documentation of any wrongdoing by the detective.

A Black female detective, who was terminated shortly after the city hired a new police chief, can proceed to trial with her Title VII retaliation claim against the city, a federal district court in Mississippi ruled. Denying the city’s motion for summary judgment, the court ruled a jury could find the city’s reasons for her termination were pretextual where the new chief started questioning her performance and initiating disciplinary action two days after learning she filed an EEOC charge. The court also denied the city’s motion for summary judgment on her state-law claim of intentional interference of business relationships against the chief where there were factual disputes about phone calls he made to other police departments to discuss her potential employment after her termination (Carter v. City of McComb, Mississippi, No. 5:24-cv-56-DCB-LGI (S.D. Miss. Oct. 10, 2025)).

Starting in 2009, the Black female worked at the McComb Police Department as a patrolman and was later promoted to detective. During the tenure of two police chiefs, she never received a negative or unsatisfactory performance review.

New chief. In June 2023, the city hired a new police chief. Shortly after he began his employment, he learned the detective was “being sued by a murder suspect” for “something to do with falsifying information.” After discussing the detective’s actions with the district attorney, the chief signed an intent to impose a disciplinary letter on the detective. In support of his accusations in the letter, he cited to examples of her conduct, including the alleged falsified affidavit, an incident where she faced a wall when he was speaking to her, and an allegation that she did not use the appropriate avenue to submit an accident report.

EEOC charge. Also in June 2023, the detective filed a discrimination charge with the EEOC. She complained of gender, race, and wage discrimination.

Termination, lawsuit. After a hearing on the merits of the disciplinary letter, the detective received a termination letter. Thereafter, she filed suit against the City of McComb for retaliation under Title VII and pay discrimination in violation of the EPA. She also filed a claim against the chief for intentional interference of business relationships. The city and chief filed this motion for summary judgment.

Wage discrimination. First, the court dismissed the detective’s wage discrimination claim with prejudice because she had abandoned the claim.

Retaliation. Turning to the detective’s retaliation claim, the court denied the city’s motion for summary judgment because a jury could find the city’s proffered reasons for her termination were pretextual.

The court found the detective presented a prima facie case. She engaged in protected activity when she filed an EEOC charge, which alleged the McComb Police Department discriminated against her. She also suffered an adverse employment action when she was terminated from her detective position.

In addition, there was a causal connection between her protected activity and termination. Prior to the current chief’s employment with the McComb Police Department, the detective was never issued a negative or unsatisfactory performance review. Yet, shortly after the current chief assumed office, and just two days after the city was notified of her EEOC charge, he began to question her performance. The sudden shift strongly reinforced the close temporal proximity between the filing of the charge and the adverse employment action, the court said. Given this timing, the court found an inference of retaliation was plausible.

Reasons for termination. Turning to the city’s legitimate, nondiscriminatory reasons for the detective’s termination, the court found a jury could find the reasons were pretext. The city cited various reasons, including the alleged falsified affidavit and an allegation that she did not use the appropriate avenue to submit an accident report. However, the city submitted no documentation of any wrongdoing by the detective in relation to these claims. In addition, the chief testified that when he assumed his position with the McComb Police Department, “all police department employees were on a clean state.”

Further undermining the justifications for her termination was the testimony of the former police chief. He described her as the “centerpiece of that office” and said people trusted and respected her. He also testified that no one ever approached him for input regarding her performance prior to her termination.

Given the absence of documentary support, the inconsistency between the chief’s testimony and his asserted reliance on prior alleged misconduct despite instituting a “clean slate,” and the credibility of the former chief’s testimony regarding the detective’s professionalism and reputation, the court found a jury could reject the reasons as pretextual. Thus, whether the stated reasons were genuine or merely a cover for retaliation must be resolved by a jury, the court said.

State-law claim. Finally, turning to the intentional inference with business relations claim, the court found the detective established a prima facie case, and there were genuine issues of material fact for a jury to decide. As such, it denied the city’s summary judgment motion.

Reviewing the four elements needed to establish a prima facie case of the claim, the court found the detective met the first one—whether the chief committed intentional and willful acts. The chief made phone calls to other police departments regarding the detective’s potential employment. The detective claimed she was denied employment at the other departments because the chief told them she “wasn’t a good fit.” The chief’s testimony conflicted with her claim. The court found it was up to a jury to determine what the content of the calls truly was.

Acts calculated to cause damage. Likewise, regarding the second element, there was a genuine issue as to whether the chief’s calls were intended to cause damage to her reputation. Based on the information the detective provided in support of her retaliation claim, a jury could find the city terminated her for filing the EEOC charge. If the jury found that, it also could find that the chief’s stated reasons for making the calls were merely a cover for his retaliation and his actions were intended to cause damage to her reputation. The court found conflicting testimony existed, and it must be heard and weighed by a jury.

Unlawful purpose. The analysis under the third element—whether the acts were done with an unlawful purpose—was the same as the analysis for the second element, the court said. Because the purpose of the calls and the content within were genuine issues of material fact, this issue was best left for a jury to decide.

Actual damage and loss. Regarding the fourth element, the detective presented sufficient evidence for a jury to find she suffered a loss in pay. Following her termination, she obtained a job at another police department working as a patrolman. She claimed she received a decrease in her salary. The discrepancy could be a result of the chief’s actions and communications with her potential employers. This matter is best left for a jury to decide, the court concluded.

The case is No. 5:24-cv-56-DCB-LGI.

Judge: Bramlette, D.

Attorneys: Jim D. Waide, III (Waide & Associates) for Victoria J. Carter. Clark Hicks (Hicks Law Firm) for City of McComb, Mississippi, and Juan Cloy.

Companies: City of McComb, Mississippi

Cases: Discrimination Retaliation Discharge PayDiscrimination StateLawClaims TortClaims MississippiNews