Brooks v. Clinton, 841 F. Supp. 2d 287

Brooks, an African-American Administrative Officer at State (Nov 2003–Mar 2007) under a renewable contract up to five years; contract last renewed Apr 2006–Mar 2007.
Supervisor change in 2006 from Brian Clark to Spinale (white) and Coquis (Hispanic) allegedly worsened conditions.
Plaintiff alleges racial discrimination, hostile work environment, retaliation for EEO activity, and failure to accommodate an eye disability.
Defendant argues legitimate, non-discriminatory reasons for the contract non-renewal and for challenged actions; claims should fail under McDonnell Douglas framework.
The court denied summary judgment on retaliation, but granted summary judgment for defendant on discrimination, hostile environment, and disability accommodation claims.
Scheduling/order issues and discovery matters are noted but do not alter the dispositive rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether actions alleged were adverse employment actions under Title VII	Brooks: several incidents show discriminatory impact	Coquis/Spinale actions were not materially adverse	Discrimination claims fail; most acts were not adverse actions.
Whether the hostile environment claim survives summary judgment	Tenor of conduct created a racially hostile environment	Isolated incidents and management style do not amount to pervasive hostility	Hostile work environment claim dismissed.
Whether Brooks state a prima facie retaliation claim	Informal EEO complaints in Nov 2006 and proximity to non-renewal show causation	Non-renewal followed legitimate concerns; timing not enough	Retaliation claim survives at summary-judgment stage; trial warranted.
Whether Brooks proved a Rehabilitation Act failure to accommodate	Requested accommodation for eye disability (Dec 2006 onward)	No disability shown; insufficient evidence of substantial limitation	Disability/failure-to-accommodate claim granted summary judgment for defendant.

Jackson v. Gonzales, 496 F.3d 703 (D.C. Cir. 2007) (requires adverse action and causal link for discrimination)
Brady v. Office of Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (McDonnell Douglas framework; burden shifts after legitimate reason)
Diggs v. Potter, 700 F. Supp. 2d 20 (D.D.C. 2010) (applies retaliation standard; proximity can show causation)
Taylor v. Solis, 571 F.3d 1313 (D.C. Cir. 2009) (biweekly reporting not an adverse action; minor inconvenience)
Lytes v. D.C. Water & Sewer Auth., 572 F.3d 936 (D.C. Cir. 2009) (definitional standards for disability under Rehabilitation Act/ADA)