2:22-cv-00384
E.D. Va.Jul 29, 2025Background
- Faline Arnold, proceeding pro se, sued her former employer Huntington Ingalls Incorporated (HII) alleging Title VII sexual harassment/hostile work environment, retaliation, interference with the Family and Medical Leave Act (FMLA), FMLA retaliation, and constructive discharge.
- Arnold worked as a deck electrician at Newport News Shipbuilding, a division of HII, from November 2019 to September 2021.
- Arnold’s claims involved allegations of sexual harassment by coworkers (Gatling and Cressman), alleged retaliation and constructive discharge, as well as denied FMLA leave to care for her disabled mother.
- Summary judgment was sought by HII. The court imposed sanctions limiting Arnold’s use of documentary evidence due to her discovery conduct, and much of Arnold's summary judgment opposition was unsupported by admissible evidence.
- The court considered only facts properly supported by sworn deposition testimony and admissible documents.
- The court concluded that Arnold failed to provide sufficient evidence to establish her claims, and that summary judgment should be granted for HII on all remaining counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hostile environment (Gatling/Cressman harassment) | Suffered unwelcome sexual harassment | No admissible evidence of harassment or timely EEOC charge | No evidence for Gatling; Cressman claim untimely |
| Constructive discharge | Working conditions were intolerable | No intolerable conditions at resignation | Not intolerable; employer acted appropriately |
| Title VII Retaliation | Suffered adverse action after reporting | No causal link between complaint and transfer; legitimate reasons | No causal connection; no retaliation |
| FMLA Interference & Retaliation | Entitled to leave, denied for retaliation | Not entitled to FMLA; no pretext | Not entitled to FMLA, no evidence of retaliation |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (burden of proof at summary judgment)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (hostile work environment standard)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for Title VII claims)
- Pa. State Police v. Suders, 542 U.S. 129 (constructive discharge standard)
- Okoli v. City of Baltimore, 648 F.3d 216 (hostile environment elements)
- Evans v. Int'l Paper Co., 936 F.3d 183 (constructive discharge standard)