Giles v. Transit Employees Federal Credit Union
417 App. D.C. 159
| D.C. Cir. | 2015Background
- Giles worked at Transit Employees Federal Credit Union (TEFCU) from 2005–2009, enrolled in TEFCU’s CareFirst PPO health plan, and has Multiple Sclerosis treated with costly infusions through 2009.
- Giles received mixed performance reviews (2008: low ratings and discipline for customer altercations; 2009: overall FAR but PAR for scanning/record-keeping with documented indexing errors).
- CEO transition: Rita Smith became CEO in Nov. 2009; on Nov. 24, 2009 Smith terminated Giles after a recommendation from predecessor Percys Felder, who cited performance issues (notably a scanning mistake).
- Giles sued under the ADA, DCHRA, and ERISA § 510, alleging she was fired to reduce health insurance costs tied to her MS treatment.
- District court granted summary judgment for TEFCU; the D.C. Circuit affirmed, concluding no reasonable jury could find TEFCU fired Giles because of the cost of insuring her.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Giles was terminated because of disability-related insurance costs (ADA/DCHRA) | Giles: termination was motivated by desire to cut insurance costs caused by her MS treatment | TEFCU: terminated for poor performance (documented reviews and scanning errors) | Court: No reasonable jury could infer cost-of-insurance motive; summary judgment for TEFCU affirmed |
| Whether ERISA § 510 protects against termination to reduce insurance costs | Giles: termination interfered with use of employee health plan | TEFCU: no intent to interfere; no evidence employer knew claims/costs (plan was fully insured) | Court: Plaintiff failed to show employer-specific intent or evidence that costs affected premium; claim fails |
| Whether TEFCU’s shifting explanations and evidentiary gaps create triable issue of pretext | Giles: inconsistent justifications and missing documents (alleged spoliation) show pretext | TEFCU: offered legitimate non-discriminatory reasons; other corroborating evidence (co-terminations, testimony) | Court: While explanations shifted (weak rebuttal), overall evidence does not permit inference that discrimination was the real reason |
| Whether discovery sanctions were warranted for alleged spoliation of insurance records | Giles: TEFCU/spoliation deprived her of evidence supporting ERISA/ADA claims | TEFCU: sufficient premium documentation provided by CareFirst; discovery hold need limited scope | Held: District court did not abuse discretion denying sanctions; appeal denied |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for burden-shifting in discrimination cases)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (assessment of pretext and when judgment as a matter of law is appropriate)
- Brady v. Office of Sergeant at Arms, 520 F.3d 490 (after employer proffers legitimate reason, focus is on whether plaintiff shows that reason is pretext)
- Adeyemi v. District of Columbia, 525 F.3d 1222 (appellate standard for ADA claim review and application of McDonnell Douglas)
- Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (assessment of totality of circumstances when evaluating pretext)
- Geleta v. Gray, 645 F.3d 408 (shifting or inconsistent employer explanations can support inference of pretext)