Case Explained: MITCHELL WATERS v. THE MAYOR AND CITY COUNCIL OF BALTIMORE

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-24 The Fourth Circuit affirmed the district court’s grant of summary judgment in favor of the City of Baltimore on all of Mitchell Waters’s employment discrimination claims arising from disciplinary actions taken by the Baltimore City Fire Department. The court reviewed the district court’s decision de novo, applying the standard that summary judgment is appropriate only if there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. In analyzing Waters’s race and color discrimination claims under Title VII, 42 U.S.C. §§ 1981–83, and the Maryland Fair Employment Practices Act (MFEPA), the court applied the *Perkins* prima facie framework, which requires proof that similarly situated employees outside the protected class received less severe discipline for comparable misconduct. The court held that Waters failed to establish a genuine issue of material fact regarding this fourth prong because his appellate brief was devoid of legal authority and failed to demonstrate that his alleged comparators engaged in conduct of comparable seriousness absent mitigating circumstances. Specifically, the court found that delays in administrative processing did not constitute less severe discipline, that allegations regarding “late charges” were unsupported by evidence beyond conclusory pleadings, and that anonymous harassment could not be compared to investigations of identified complaints. Regarding the hostile work environment claim, the court affirmed summary judgment because Waters failed to create a genuine dispute that the alleged harassment was sufficiently severe or pervasive or that it was imputable to the employer. The court noted that while anonymous racist messages were related to race, Waters could not link them to specific coworkers or demonstrate that the City knew of the harassment and failed to take effective remedial action, particularly given the City’s investigation into the anonymous complaints. Finally, the court affirmed the dismissal of the retaliation claim because Waters waived his argument by failing to develop the legal basis for the causal connection between protected activity and adverse actions in his appellate brief, offering only a perfunctory assertion that evidence should be viewed in the light most favorable to him. As a result of this decision, the judgment of the United States District Court for the District of Maryland is upheld, leaving Waters without relief on his employment discrimination claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.