Geleta v. Gray
396 U.S. App. D.C. 87
| D.C. Cir. | 2011Background
- Geleta helped obtain a DC CINGS grant and became Project Director supervising ~20 staff (2002).
- In 2004–2005, HHS site visit and reports identified compliance issues; a follow-up was planned and funding risk noted.
- Geleta corroborated Spriggs’s racial discrimination claim at a January 2005 EEOC investigation.
- In early 2005, Geleta was transferred from DC CINGS to the Office of Accountability, losing supervisory responsibilities and facing narrowed duties.
- Geleta later held OA roles with different duties, ultimately becoming Residential Treatment Center Certification and Monitoring Projects Manager at OA (grade/bonus unchanged for a time).
- Geleta filed a Title VII retaliation suit in October 2006; the district court granted summary judgment for the District.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the transfer was a materially adverse action | Geleta lost supervisory duties and high-responsibility work | New OA duties were comparable in pay and prestige | Yes, could be material adverse action capable of supporting retaliation claim |
| Whether District's reasons were pretextual | Reasons shifted over time; realignment not credibly tied to funding | Transfer tied to program realignment to comply with funding mandates | Yes, issues of pretext could defeat summary judgment when viewed with all evidence |
| Whether evidence supports causation from protected activity to adverse action | Transfer followed Geleta's support of Spriggs's complaint | Transfer based on program restructuring and funding concerns | Yes, causal link present under McDonnell Douglas framework |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes framework for retaliation claims)
- Brady v. Office of Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (retaliation analysis under McDonnell Douglas; consider all evidence)
- Jones v. Bernanke, 557 F.3d 670 (D.C. Cir. 2009) (retaliation framework applied in this circuit)
- Gaujacq v. EDF, Inc., 601 F.3d 565 (D.C. Cir. 2010) (three-part prima facie framework and evidence review)
- Czekalski v. Peters, 475 F.3d 360 (D.C. Cir. 2007) (withdrawal of supervisory duties constitutes adverse action; pretext considerations)
- Pardo-Kronemann v. Donovan, 601 F.3d 599 (D.C. Cir. 2010) (definition of materially adverse action; reasonable worker dissuasion standard)
- Burlington Northern & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (scope of material adversity in employment actions)
- EEOC v. Sears Roebuck & Co., 243 F.3d 846 (4th Cir. 2001) (pretext evidence from shifting explanations)
- Lathram v. Snow, 336 F.3d 1085 (D.C. Cir. 2003) (pretext analysis and evidence standard)