Huckstep v. Washington Metropolitan Area Transit Authority
216 F. Supp. 3d 69
| D.D.C. | 2016Background
- Huckstep, hired as a WMATA bus operator in Oct. 2013, was in a 90-day probationary period when she struck another vehicle on Jan. 29, 2014; WMATA rated the accident Preventable–Major and terminated her on Feb. 11, 2014.
- Video showed she accelerated through an intersection as the light changed and did not look left/right; other vehicle suffered moderate damage and driver reported pain; Huckstep was placed on paid leave during investigation.
- WMATA’s policies treat probationary discipline as discretionary (may discipline or discharge); its disciplinary scheme distinguishes Preventable–Minor and Preventable–Major with different recommended sanctions.
- Huckstep sued under Title VII alleging gender discrimination, pointing to four male training-class colleagues (Davis, Coates, Farmer, Butler) who had Preventable–Minor accidents during their probationary periods and were not terminated.
- Court focused on whether Huckstep produced sufficient evidence (under Brady modified McDonnell Douglas analysis) that WMATA’s nondiscriminatory reason (serious preventable accident) was pretext for sex discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WMATA had an automatic-termination policy for any probationary-period accident | Huckstep alleged policy that any accident in first 90 days may result in immediate termination (implying unequal application) | WMATA: no categorical rule; discipline/discharge is discretionary per CBA and disciplinary policy | Court: No genuine dispute that no automatic-termination rule existed; Huckstep abandoned or lacks evidence for a categorical rule. |
| Whether similarly situated male comparators received more favorable treatment (showing pretext) | Huckstep: four male trainees had preventable accidents in probation but were not fired, implying disparate treatment | WMATA: comparators’ accidents were materially less serious and/or involved different supervisors; not similarly situated | Court: Comparators are inapt—each male’s accident was Preventable–Minor vs Huckstep’s Preventable–Major, and some had different supervisors—cannot support inference of sex-based pretext. |
| Whether female comparator (Bowlding) shows pattern of discrimination against women | Huckstep referenced another terminated female as evidence of disparate treatment of women | WMATA: no factual record on Bowlding’s circumstances; female comparator cannot show disparate treatment in favor of plaintiff | Court: Bowlding is not a valid opposite-sex comparator; Huckstep failed to submit evidence to show a pattern of discrimination among women. |
| Whether totality of evidence permits a reasonable jury to infer intentional sex discrimination | Huckstep: combination of alleged policy and comparator treatment creates inference of pretext | WMATA: articulated legitimate, nondiscriminatory reason (serious preventable accident); record lacks evidence of dishonest explanations or pattern of sex-based bias | Held: No—totality of record does not permit a reasonable jury to find WMATA’s reason was pretext; summary judgment for WMATA. |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard; genuine dispute and materiality)
- Scott v. Harris, 550 U.S. 372 (viewing facts in light most favorable to nonmovant and assessing record evidence)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination cases)
- Brady v. Office of Sergeant at Arms, 520 F.3d 490 (central-question approach when employer proffers nondiscriminatory reason)
- Wheeler v. Georgetown Univ. Hosp., 812 F.3d 1109 (requirements for comparator similarity)
- St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (plaintiff retains burden of persuasion)
- Laningham v. U.S. Navy, 813 F.2d 1236 (nonmovant must produce affirmative evidence)
- Aka v. Wash. Hosp. Ctr., 156 F.3d 1284 (totality-of-evidence approach)
- Walker v. Johnson, 798 F.3d 1085 (methods to show pretext; comparators and patterns)
- Burley v. Nat’l Passenger Rail Corp., 801 F.3d 290 (comparators must be charged with offenses of comparable seriousness)
- George v. Leavitt, 407 F.3d 405 (court may decide comparator similarity as matter of law)
- Wilson v. Wash. Metro. Area Transit Auth., 631 F. Supp. 2d 58 (comparator inapt where misconduct not comparable)
- Williams v. Chertoff, 495 F. Supp. 2d 17 (inapt comparator where misconducts materially differ)