Caudle v. District of Columbia
2011 U.S. Dist. LEXIS 92590
D.D.C.2011Background
- In 2006, five MPD officers in the First District FMU alleged race-based discrimination by Caucasian supervisor Wilkins after an anonymous June 16, 2006 letter and a later August 24, 2006 complaint.
- Groomes, the First District Commander, reorganized the FMU, requiring reapplication to remain in the unit and ultimately denying all five plaintiffs’ FMU applications and transferring them to patrol or the Intel unit.
- Caudle, James, Miller, Smalls, and Goins were African American; Miller sought a day shift transfer to care for her child, which was denied.
- After the reorganization, plaintiffs experienced diminished responsibilities and less favorable assignments, leading to the 2008 lawsuit filed February 2008.
- A three-week jury trial in June–July 2010 found retaliation under Title VII, awarding Caudle and Goins $200,000 each, James and Smalls $250,000 each, and Miller nothing; the District then moved for judgment as a matter of law, new trial, and remittitur, which the court denied in August 2011.
- The court’s decision addresses whether protected activity was proven, whether actions were materially adverse, the causation/pretext linkage, Miller’s transfer denial, and challenges to damages and trial conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Protected activity established | Caudle, James, Miller, Smalls, Goins engaged in protected activity via the June 16 letter and August 24 complaint, plus Goins’ oral complaints. | Unsigned letter could not be attributed to plaintiffs; lack of knowledge by Groomes defeats protected activity. | Protected activity established for all plaintiffs; Goins’ oral complaints and the 8/24 complaint also protected. |
| Materially adverse action | FMU reorganization, denial of FMU reapplications, and Goins’/Caudle's/James'/Smalls' transfers were adverse actions. | Some actions were neutral or only lateral; changes did not amount to material adversity in all circumstances. | Cumulative FMU reorganization and individual moves constituted materially adverse actions; Miller’s shift denial also materially adverse. |
| Causal connection/knowledge of protected activity | MPD knew of the protected activities and acted with a pattern of antagonism supports causation. | Unsigned letter and anonymous nature negate knowledge; denial could be unrelated. | Sufficient evidence of employer knowledge and a causal link, supported by pretext and pattern of conduct. |
| Denial of Miller’s transfer | Unexplained reversal after initial agreement and timing with complaints supports retaliation inference. | Denial explained by non-retaliatory reasons not credibly shown. | Denial supported by timing, reversal, and vacancy context; supports causation. |
| Damages/remittitur and trial conduct | Damages reflect emotional and professional impact; back-pay charts not sole basis; no shock to conscience. | Remittitur or damages should be reduced; charts misused to cap damages; trial errors. | Remittitur denied; damages supported by trial record and not shockingly excessive. |
Key Cases Cited
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (materially adverse action requires dissuading a reasonable worker from filing a discrimination claim)
- Forkkio v. Powell, 306 F.3d 1127 (D.C.Cir. 2002) (reassignment with significant changes can be adverse action)
- Czekalski v. Peters, 475 F.3d 360 (D.C.Cir. 2007) (adverse action can be found even for lateral transfers)
- Geleta v. Gray, 645 F.3d 408 (D.C.Cir. 2011) (pretext evidence can support retaliation inferences when explanations are inconsistent)
- Aka v. Wash. Hosp. Ctr., 156 F.3d 1284 (D.C.Cir. 1998) (en banc; credibility of employer's reasons matters for pretext)
- Colbert v. Tapella, 649 F.3d 756 (D.C.Cir. 2011) (pretext and causation principles in Title VII retaliation)
- Jones v. Bernanke, 557 F.3d 670 (D.C.Cir. 2009) (knowledge and inference in causation analysis)