Hampton v. Vilsack
791 F. Supp. 2d 163
D.D.C.2011Background
- Hampton, an African-American Foreign Service Officer, was terminated for allegedly submitting altered hotel receipts for reimbursement.
- Hampton sued USDA under Title VII for discrimination, retaliation, and hostile work environment; ten counts originally filed
- The Court granted summary judgment on nine counts; only Count Five (non-promotion/foreign assignment) remained
- Staub v. Proctor Hospital issued March 1, 2011, addressing USERRA “cat’s paw” liability and proximate cause
- Hampton filed a motion for reconsideration on April 4, 2011, arguing Staub changed controlling law
- The Court denied reconsideration, finding Staub did not require reversal of the prior ruling; the remaining issues centered on pretext and proximate cause
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Staub requires reversal under Rule 60(b)(1). | Hampton contends Staub shows proximate cause by supervisor actions. | Hampton misreads Staub; no proximate cause shown for termination. | No reversal; Staub not controlling on Title VII pretext here. |
| Whether Miller’s actions proximate to termination show discriminatory animus under Staub. | Miller’s animus tainted the actions leading to termination. | Miller’s actions were too remote; not proximate cause. | Barred; Miller’s actions not proximate cause of termination. |
| Whether the evidence supports pretext for the termination decision. | Prosecution of altered receipts shows pretext; disciplinary history irrelevant. | Investigation and findings show falsified travel reimbursement; no pretext. | No material dispute; later findings support non-pretext rationale. |
| Whether the leave-without-pay and termination decisions were properly sustained. | Staub would imply pretext for those decisions. | Henwood not deciding official; reasons for termination remain. | Insufficient to show Staub-based reversal; pretext not established. |
Key Cases Cited
- Staub v. Proctor Hospital, 131 S. Ct. 1186 (2011) (USERRA proximate causation; supervisor actions can trigger employer liability)
- Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (2000) (pretext evidence; ultimate falsity of employer's explanation can show liability)
- Hemi Group, LLC v. City of New York, 130 S. Ct. 983 (2010) (proximate cause standard; not too remote or indirect)
- Volpe v. DC Fed’n of Civic Ass’ns, 520 F.2d 451 (D.C. Cir. 1975) (Rule 60(b) reconsideration based on intervening controlling law)