Coats v. Duncan, 232 F. Supp. 3d 81

Background

Ronald Coats, an African-American systems accountant (age 59), worked at the Department of Education from 1991 until termination in early 2013; his direct supervisor from March 2011 was Phillip Juengst and the deciding official was Administrative Judge Ernest Canellos.
Juengst issued an "unsatisfactory" REACH rating (Sept. 2011), placed Coats on a PIP, proposed removal (Feb. 2012), rescinded the 2011 removal after an internal EEO review raised a timing error, then re-initiated removal proceedings in Sept. 2012; Canellos ultimately removed Coats in Feb. 2013.
Coats filed an EEO complaint in Nov. 2011 alleging race and age discrimination and retaliation; the Office of Management found no discrimination but identified procedural errors and pervasive problems in Coats’s work product.
Coats alleges (1) Juengst told him in Oct. 2012, "Frankly, Ron, it’s because of your race and salary," which Coats contends is direct evidence of racial discrimination and retaliation; Juengst denies the remark.
The Department asserts the termination was for legitimate, nondiscriminatory reasons: sustained poor performance documented in evaluations and PIPs; it also emphasizes that Canellos independently reviewed the record before deciding to remove Coats.
Court framed summary-judgment review in plaintiff’s favor on disputed facts and distinguished Title VII (race/retaliation) and ADEA (age/retaliation) claims for different outcomes.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Juengst's alleged statement is direct evidence of race discrimination under Title VII	Coats says Juengst told him termination was because of his race, a direct comment tying motive to the adverse action	Dept. says Juengst denies the remark or it was a stray/frustrated remark not showing bias	Court: Issue genuine for jury; statement qualifies as direct evidence; summary judgment denied on Title VII discrimination
Whether Juengst's alleged bias can be imputed to the ultimate decisionmaker ("cat’s paw")	Coats: Juengst drafted removal notices, gathered materials, and influenced Canellos; thus his bias could be a proximate cause	Dept.: Canellos conducted an independent review; his independent judgment breaks any causal chain	Court: Material factual dispute; Staub doctrine applies; jury could find Juengst's influence proximate — summary judgment denied on Title VII discrimination
Whether Coats proved age discrimination under the ADEA	Coats points to retirement references, prior good record, short supervisory relationship, and comparators treated better	Dept. shows substantial documented performance problems, earlier poor ratings, differences in grade/performance expectations between comparators	Court: No adequate evidence of age-based motive or nearly identical comparators; summary judgment granted for Dept. on ADEA discrimination
Whether termination was retaliation for prior EEO activity (Title VII and ADEA)	Coats contends Juengst's alleged comment mocked his EEO complaint and shows retaliatory animus	Dept. stresses independent decisionmaking and lack of age-related retaliatory evidence	Court: Title VII retaliation — disputed fact (remark could be retaliation) so summary judgment denied; ADEA retaliation — no evidence tying retaliation to age, summary judgment granted

Key Cases Cited

Arrington v. United States, 473 F.3d 329 (D.C. Cir.) (summary-judgment evidence viewed in light most favorable to nonmoving party)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (defendant’s initial burden on summary judgment)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (materiality and genuine dispute standards for summary judgment)
Staub v. Proctor Hosp., 562 U.S. 411 (2011) ("cat’s paw" liability — supervisor bias can be proximate cause of adverse action)
Morris v. McCarthy, 825 F.3d 658 (D.C. Cir. 2016) (application of Staub and limits of independent-investigation defense)
Wilson v. Cox, 753 F.3d 244 (D.C. Cir. 2014) (direct evidence standard in Title VII cases)