Harrison v. Office of the Architect of the Capitol
68 F. Supp. 3d 174
D.D.C.2014Background
- Harrison filed Harrison I (July 23, 2009) alleging discrimination under 2 U.S.C. § 1311(a)(1) and retaliation under § 1317(a).
- Harrison II (August 31, 2010) and Harrison III (February 23, 2011) followed, alleging ongoing retaliation; the court later granted summary judgment in all three actions.
- The instant motion challenges the court’s denial of reconsideration regarding five hostile work environment claims under the CAA, with events between August 6, 2008 and July 23, 2009.
- The court previously held that the CAA defenses are analyzed under Title VII standards and denied reconsideration for record aggregation, medical evidence, and broader CAA interpretations.
- This memorandum incorporates the prior reasoning and resolves the motion to deny reconsideration, keeping the case dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should consider records from Harrison II and Harrison III together with Harrison I | Harrison argues for aggregate consideration across all three cases. | Defendant contends no legal support for aggregating records beyond Harrison I. | denied: no aggregate consideration for findings in Harrison I. |
| Whether medical evidence from the August 6, 2008 incident should alter the ruling | Harrison asserts medical evidence supports hostile environment. | Medial evidence does not create genuine issues on gender discrimination or retaliation. | denied: medical evidence does not create material fact issues. |
| Whether Title VII case law should be applied to CAA claims | CAA broader protections justify diverging from Title VII standards. | Title VII precedent appropriately applies to CAA claims. | denied: Title VII standards appropriately applied. |
Key Cases Cited
- Blackmon-Malloy v. United States Capitol Police Bd., 575 F.3d 699 (D.C. Cir. 2009) (CAA incorporates Title VII; Board decisions not binding on this court)
- Brady v. Office of the Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (Title VII applies to the legislative branch through the CAA)
- Duncan v. Office of the Architect of the Capitol, 541 F.3d 1377 (Fed. Cir. 2008) (Federal Circuit acknowledges CAA/Title VII interplay; Board standard not controlling)
- Burlington Northern & Santa Fe Ry. v. White, 548 U.S. 53 (S. Ct. 2006) (Supreme Court: materially adverse standard for retaliation)