EMPLOYER DISCRIMINATION; EVIDENCE OF UNLAWFUL MOTIVATION; NEXUS – Cursory Investigation

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Failure to investigate supervisor’s reasons for recommending employee’s release on probation did not support an inference of unlawful motive. A decisionmaker’s reliance on reports by subordinates does not constitute a cursory investigation unless the decisionmaker had reason to believe the reports to be biased or inaccurate. Nothing in the record demonstrates that decisionmaker had any reason to believe supervisor’s reports were not truthful. Recommendations were based on statements employee made to supervisor, not on the incidents themselves. Thus, an investigation into the substance of the incidents would not have addressed the actual reasons for the supervisor’s recommendation. Employer’s failure to interview employee did not evidence unlawful motive, where there was no evidence that the employer regularly interviewed probationary employees before releasing them.