The U.S. Court of Appeals for the Sixth Circuit affirmed a district court's grant of summary judgment to Delta Air Lines and two of its employees in a race discrimination case filed by flight attendant Jacqueline Meadows. The Jan. 29, 2026 decision rejected Meadows' claims under both Title VII of the Civil Rights Act of 1964 and Michigan's Elliott-Larsen Civil Rights Act.
Meadows alleged that Delta Air Lines, along with employees Christian Gunn and Peter Saballa-Davis, engaged in race discrimination through disciplinary actions taken against her following a workplace incident with another Delta flight attendant. The three-judge panel consisting of Circuit Judges Julia Smith Gibbons, Joan Larsen, and David Murphy unanimously upheld the lower court's ruling.
According to court documents, Meadows began her aviation career with Northwest Airlines in 1989 as a full-time employee before transitioning to Delta Air Lines when the two carriers merged in 2008. At the time of the incident that sparked the lawsuit, Meadows held the position of "purser-qualified" flight attendant, a senior role that made her the "on-board leader" responsible for managing cabin operations during flights.
The case stemmed from disciplinary actions Delta took against Meadows following what court records describe as a "workplace incident with another Delta flight attendant." While the specific details of the incident are not fully outlined in the available court documents, Meadows contended that the discipline she received was motivated by racial discrimination rather than legitimate workplace conduct concerns.
In her federal lawsuit, Meadows pursued claims under two separate legal frameworks. She alleged violations of Title VII of the Civil Rights Act of 1964, the federal law that prohibits employment discrimination based on race, color, religion, sex, or national origin. Additionally, she brought claims under Michigan's Elliott-Larsen Civil Rights Act, the state's comprehensive civil rights statute that mirrors many federal protections and provides additional remedies for discrimination victims.
The defendants successfully argued at the district court level that Meadows' claims lacked sufficient evidence to proceed to trial. Summary judgment is typically granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. This procedural mechanism allows courts to resolve cases without a full trial when the evidence clearly favors one side.
Circuit Judge Julia Smith Gibbons wrote the opinion for the Sixth Circuit panel. In affirming the district court's decision, the appeals court found that Meadows had failed to present evidence sufficient to create a genuine issue of material fact regarding her discrimination claims. The court's analysis would have examined whether Meadows could establish the elements necessary for both her Title VII and state law claims.
Under Title VII, employment discrimination plaintiffs must typically show they belong to a protected class, were qualified for their position, suffered an adverse employment action, and that the action occurred under circumstances giving rise to an inference of discrimination. Plaintiffs can prove discrimination through direct evidence or by establishing a prima facie case under the burden-shifting framework established in *McDonnell Douglas Corp. v. Green*.
The Elliott-Larsen Civil Rights Act follows similar analytical frameworks to federal civil rights law, though it may provide broader protections or different remedies in certain circumstances. Michigan courts often look to federal Title VII precedent when interpreting the state statute, given their similar purposes and language.
The Sixth Circuit's decision represents the final resolution of Meadows' discrimination claims unless she seeks further review from the Supreme Court, which accepts only a small percentage of cases for review. The ruling is designated as "not recommended for publication," meaning it will not serve as binding precedent for future cases, though it may be cited for its persuasive value.
Employment discrimination cases involving airlines and flight attendants raise unique workplace dynamics given the highly regulated nature of the aviation industry and the safety-sensitive responsibilities of cabin crew members. Airlines maintain significant discretion in disciplining employees for conduct that could affect flight safety or customer service, though such actions must still comply with federal and state civil rights laws.
The case highlights the challenges employment discrimination plaintiffs face in federal court, where summary judgment is frequently granted in favor of employers. Recent data shows that employment discrimination cases have among the lowest success rates of any type of federal civil litigation, with many cases resolved through summary judgment rather than proceeding to trial.
For Delta Air Lines, the decision concludes what could have been costly litigation and potential damages exposure. The airline, formed through the 2008 merger of Delta and Northwest Airlines, employs thousands of flight attendants and other aviation workers across the United States and maintains comprehensive policies governing workplace conduct and discipline.
The ruling also affects the individual defendants, Gunn and Saballa-Davis, who were named alongside Delta in the lawsuit. Individual supervisors and managers can face personal liability under certain civil rights statutes, making their inclusion in such lawsuits a common litigation strategy.