BATTLE v. TRULAND SYSTEMS CORPORATION, 1:12-cv-00106

Plaintiff Keith Battle, an African American journeyman electrician, began work for Truland on the Washington Nationals stadium project in November 2007.
A noose incident involving electrical wire occurred January 22, 2008, prompting management to terminate the employees involved and to issue public and private apologies.
Plaintiff and others reported racial graffiti and inappropriate racial comments; management addressed these incidents, including firing the Mahogany Interior employee responsible for the comments.
In March 2008, Plaintiff was promoted to subforeman but fought over pay and duties; he later filed an EEOC charge alleging race discrimination and retaliation, which led to retroactive pay adjustments.
In June 2008, as the stadium project ended, Plaintiff was reassigned to the One Noma project (at his request) rather than GEICO; the reassignment occurred as Truland laid off many workers.
Plaintiff’s employment with Truland ended on July 3, 2008 so that he could accept a position with Nationwide; Nationwide terminated him in August 2008; he later worked for VARCO/MAC and remained on union-out-of-work lists, with the union referral system governing referrals and rehiring eligibility; Plaintiff was never referred by the union to Truland after 2008 and was not rehired by Truland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Disparate treatment under §1981	Battle contends race-based discrimination in the contractual relationship.	Truland provided legitimate, non-discriminatory reasons for reassignment, termination, and non-rehire.	Summary judgment for Truland; no triable pretext evidence shows discriminatory motive.
Retaliation under §1981	Battle claims adverse actions were caused by protected activity (complaints and disclosures).	Defendant offered legitimate, non-retaliatory reasons for actions; timing alone is insufficient.	Summary judgment for Truland; no genuine issue of material fact on retaliation.
Pretext and evidence sufficiency	Plaintiff presents emails and statements suggesting pretext for actions.	Evidence insufficient to establish pretext; remarks are stray or not probative of discriminatory intent.	Court finds no material dispute; evidence fails to show pretext; grant of summary judgment stands.

Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (D.C. Cir. 1998) (pretext evidence may be considered with prima facie case in discrimination/retaliation)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct. 1973) (burden-shifting framework for discrimination claims)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Sup. Ct. 2000) (pretext and ultimate issue of discrimination after legitimate reason)
Wiley v. Glassman, 511 F.3d 151 (D.C. Cir. 2007) (prima facie elements and inference on discrimination)
Woodruff v. Peters, 482 F.3d 521 (D.C. Cir. 2007) (temporal proximity not alone enough to defeat legitimate reasons)