GILES v. TRANSIT EMPLOYEES FEDERAL CREDIT UNION, 1:11-cv-01103

Background

Giles, a former TEFCU employee, was terminated in Nov. 2009; she alleged disability discrimination (ADA/DCHRA) and ERISA interference, with a previously dismissed public-policy claim.
She had MS and underwent costly treatments; health insurance premium costs were part of the dispute.
She had multiple prior disciplinary actions for conduct issues, including warnings and a two-day suspension in 2008.
Defendant offered a non-discriminatory, performance-based reason for termination, centered on her job performance as scanning specialist.
TEFCU presented evidence that the ultimate decision-maker relied on the prior CEO Felder’s assessment, and she was not shown to be aware of Giles’s MS.
The court granted summary judgment for the defendant on counts I, II, and IV, concluding Giles failed to raise a genuine issue of material fact on discriminatory motive.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Giles proved disability discrimination under ADA/DCHRA.	Giles argues MS caused termination; she contends employer acted with animus.	TEFCU had a legitimate non-discriminatory reason based on performance.	No; no genuine issue of material fact on discriminatory motive.
Whether ERISA §510 claim supported by evidence of intent to interfere with benefits.	Employer believed Giles’s costs raised premiums; claim discusses intent to interfere.	No evidence of specific intent or connection to termination.	No; insufficient evidence of intentional interference tied to Giles’s benefits.
Whether pretext or cat’s-paw theory could show discriminatory motive.	Felder’s and Smith’s testimony suggests bias influencing decision.	Court cannot reweigh business decisions or substitute its judgment for employer’s.	No; plaintiff failed to show that the reasons were pretextual or that a biased agent caused the decision.
Whether the evidence shows that rising health costs were the actual reason for firing Giles.	Costs allegedly rose due to Giles’s treatments; this caused termination.	Costs were not tied to Giles’s treatment costs; premiums rose for the group, not Giles specifically.	No; insufficient evidence that costs or belief about costs drove termination.
Whether the cat’s-paw theory applies to hold the company liable for animus of a subordinate.	Felder’s alleged biases were channeled to Smith in the decision.	No demonstrable discriminatory animus by the ultimate decision-maker or sponsor.	No; no evidence of discriminatory animus by the decision-maker.

Key Cases Cited

Adeyemi v. District of Columbia, 525 F.3d 1222 (D.C. Cir. 2008) (elements of ADA/DCHRA claims; McDonnell Douglas framework)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (pretext and ultimate question of discriminatory motive)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (pretext standard; burden-shifting limits)
Fischbach v. District of Columbia Dep’t of Corrections, 86 F.3d 1180 (D.C. Cir. 1996) (no second-guessing of employer’s personnel decisions absent discriminatory motive)
Barbour v. Browner, 181 F.3d 1342 (D.C. Cir. 1999) (standard for evaluating discrimination defenses under DCHRA)
Staub v. Proctor Hosp., 131 S. Ct. 1186 (2011) (cat’s-paw theory; supervisor’s bias can be imputable to employer)
Brady v. Office of Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (evidentiary standards for proving discriminatory motive)
Jones v. Bernanke, 557 F.3d 670 (D.C. Cir. 2009) (consideration of full record in discrimination analysis)
Grant v. May Dep’t Stores Co., 786 A.2d 580 (D.C. 2001) (analysis under DCHRA mirrors ADA in many respects)
Howard Univ. v. Green, 652 A.2d 41 (D.C. Cir. 1994) (DCHRA/ADA framework alignment)