Diaz v. Washington Metropolitan Area Transit Authority
243 F. Supp. 3d 86
| D.D.C. | 2017Background
- Clifton Stanley Diaz, a probationary Metro Transit Police recruit, was terminated effective June 1, 2013 after an MTPD investigation found he abandoned his Field Training Officer (FTO), failed to submit paperwork, and gave untruthful statements; MTPD also cited poor field training evaluations.
- Defendant WMATA moved for summary judgment; Diaz proceeded pro se and alleged discrimination based on national origin (Hispanic) and perceived sexual orientation.
- Diaz testified he was the only Hispanic in his training group, that a deputy chief asked if he had girlfriends, that peers used a derogatory homosexual slur about him, and that his uniform pants did not fit.
- WMATA produced documentary evidence of the investigation, the Field Training Failure Notice, and the investigative reports supporting a nondiscriminatory reason for termination.
- The district court treated Title VII as not covering sexual orientation claims but considered whether sex-stereotyping or national-origin discrimination claims could survive summary judgment.
- The court granted WMATA summary judgment, finding Diaz failed to produce sufficient evidence to show WMATA’s proffered nondiscriminatory reason was pretext for discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether termination was motivated by national origin discrimination | Diaz contends he was fired because he was Hispanic and the only Hispanic in his training group | WMATA contends Diaz was terminated for misconduct found in its investigation and poor field training performance | Court held Diaz failed to rebut WMATA’s nondiscriminatory reason; summary judgment for WMATA |
| Whether termination was motivated by sex/gender stereotyping (or sexual-orientation-related bias) | Diaz alleged being perceived as gay (questions about girlfriends, slur by peers, ill-fitting uniform) | WMATA argued these allegations are unrelated to the termination and provide no evidence of discriminatory intent | Court held the statements and uniform complaints were insufficient to show pretext; summary judgment for WMATA |
| Whether Title VII covers sexual-orientation discrimination alleged by Diaz | Diaz asserted discrimination based on sexual orientation | WMATA argued Title VII does not prohibit sexual-orientation discrimination | Court held Title VII does not prohibit sexual-orientation discrimination and dismissed any such claim |
| Whether other conduct (comments, uniform issues) constituted adverse employment actions | Diaz pointed to peer/supervisor comments and uniform issues as evidence of discrimination | WMATA argued only termination is a cognizable adverse action and other allegations are not materially adverse | Court held only termination was an adverse employment action and other complaints were not sufficient to establish discrimination |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard and credibility/weighing evidence)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (plaintiff must do more than raise metaphysical doubt to defeat summary judgment)
- Ricci v. DeStefano, 557 U.S. 557 (summary judgment burdens where plaintiff would bear burden at trial)
- Brady v. Office of Sergeant at Arms, 520 F.3d 490 (once employer proffers nondiscriminatory reason, plaintiff must produce evidence that it was pretext)
- Holcomb v. Powell, 433 F.3d 889 (evidence categories a plaintiff may use to show pretext)
- Aka v. Washington Hosp. Ctr., 116 F.3d 876 (caution in evaluating discrimination claims at summary judgment stage)
- U.S. Postal Serv. Bd. of Governors v. Aikens, 460 U.S. 711 (effect of employer’s proffered nondiscriminatory reason)
- Burlington Indus. v. Ellerth, 524 U.S. 742 (definition of actionable adverse employment action)
- Matsushita and Anderson were cited by the court for summary judgment standards; Brady and Holcomb govern the pretext framework applied here.