Muminatou Bah v. Sampson Bladen Oil Company, Inc.

── Muminatou Bah v. Sampson Bladen Oil Company, Inc. ── Court: Court of Appeals for the Fourth Circuit Date: May 29, 2026 Category: General USCA4 Appeal: 25-1877 Doc: 40 Filed: 05/29/2026 Pg: 1 of 7 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-1877 MUMINATOU BAH, Plaintiff – Appellant, v. SAMPSON BLADEN OIL COMPANY, INC., d/b/a Han-Dee Hugo’s, Defendant – Appellee. Appeal from the United States District Court for the Eastern District of North Carolina at Raleigh. Louise W. Flanagan, District Judge. (5:23−cv−00330−FL−RN) Argued: March 18, 2026 Decided: May 29, 2026 Before WILKINSON, NIEMEYER, and KING, Circuit Judges. Affirmed by unpublished per curiam opinion. ARGUED: Gilda Adriana Hernandez, LAW OFFICES OF GILDA A. HERNANDEZ, PLLC, Cary, North Carolina, for Appellant. Nathaniel J. Pencook, NELSON MULLINS RILEY & SCARBOROUGH LLP, Raleigh, North Carolina, for Appellees. ON BRIEF: Matthew S. Marlowe, Hannah B. Simmons, LAW OFFICES OF GILDA A. HERNANDEZ, PLLC, Cary, North Carolina, for Appellant. Phillip J. Strach, Jordan A. Koonts, NELSON MULLINS RILEY & SCARBOROUGH LLP, Raleigh, North Carolina, for Appellee. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-1877 Doc: 40 Filed: 05/29/2026 Pg: 2 of 7 PER CURIAM: Plaintiff Muminatou Bah brought suit against her employer, Sampson Bladen Oil Co. (“Sampson Bladen”), alleging multiple claims under Title VII and the North Carolina Retaliatory Employment Discrimination Act (“REDA”) for adverse employment actions. Specifically, Bah alleges that Sampson Bladen gave her lower-performing stores and subsequently terminated her employment based on her race and in retaliation for complaints she levied regarding overtime pay. But, in weaving her tale, Bah failed to contend with her documented history of poor communication and the egregious and disturbing conditions of one of her store locations. It was on these grounds that her employer premised her termination. Because Bah did not establish that these legitimate reasons were pretextual, and because Bah never made a qualifying REDA complaint, the district court granted summary judgment in favor of Sampson Bladen. The district court performed a careful analysis of the facts and legal standards in this case. We therefore affirm. I. The district court’s factual narrative accorded plaintiff the benefit of inferences on summary judgment, and we thus adopt the district court’s recital with appreciation. To briefly summarize, Bah, a black Gambian woman, began employment at Sampson Bladen in 2011 as a store manager. In 2017, the company promoted her to district manager. Bah received largely positive performance evaluations throughout her tenure, although her supervisors repeatedly noted that she needed to improve her communication skills. In 2021, 2 USCA4 Appeal: 25-1877 Doc: 40 Filed: 05/29/2026 Pg: 3 of 7 however, Bah’s performance evaluations suffered a noticeable decline from between “Satisfactory” and “Excellent” to between “Needs Improvement” and “Satisfactory.” J.A. 473–79, 1141. During Bah’s employment as a district manager, Sampson Bladen required her to assume supervision of Store 98 after two white district managers were allowed to decline this responsibility. Bah claims that this store was underperforming and that on