Iyoha v. Architect of the Capitol
Civil Action No. 2015-0324
| D.D.C. | Oct 25, 2017Background
- Plaintiff Sunday Iyoha, a Black Nigerian-descent Architect of the Capitol (AOC) employee, was reassigned from Help Desk Manager to Project Management in 2012 and filed an Office of Compliance (OOC) complaint in Feb. 2013 alleging national-origin discrimination; the OOC hearing officer and BOD later found discrimination and awarded damages.
- Iyoha applied for the Department Branch Chief position in 2014 and again in 2015; Angela Clark was the selecting official and various panels interviewed candidates both years.
- Iyoha was not selected in 2014 (Teddy Tseng was selected) nor advanced to the final round in 2015; some selected/advanced candidates spoke with noticeable foreign accents.
- Iyoha alleges Title VII claims (via the Congressional Accountability Act): national-origin discrimination, hostile work environment (later voluntarily dismissed), and retaliation for his prior protected activity (the OOC complaint and related proceedings).
- AOC moved for summary judgment arguing the selectees were independently determined to be better qualified; Iyoha relied on alleged prior derogatory remarks about accents, asserted manipulation of interview procedures/panels, alleged unfair scoring, and speculated AOC concealed documents.
- The Court denied Iyoha’s motion for oral argument/sur-reply and granted summary judgment for AOC on discrimination and retaliation claims, finding Iyoha’s evidence insufficient to show pretext or causal retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| National-origin discrimination (failure to hire for Branch Chief in 2014 & 2015) | Iyoha: prior disparaging remarks about accents, manipulated panels/questions/scoring, and missing documents show AOC’s qualifications rationale is pretextual | AOC: each panel independently scored candidates; selected candidates were more qualified; some selects were in same protected class (accent/foreign origin) | Court: Grant summary judgment for AOC — stray/temporal-gap remarks, lack of nexus, speculative manipulation and subjective scoring do not show pretext |
| Retaliation (non-selections caused by Iyoha’s prior OOC complaint) | Iyoha: temporal proximity between protected activity (OOC findings) and non-selections creates inference of retaliation | AOC: legitimate nondiscriminatory reasons; temporal proximity is weak/not contemporaneous to decision-making; filings by AOC (appeal) not Iyoha’s protected activity | Court: Grant summary judgment for AOC — temporal gap and lack of additional evidence preclude causal inference of retaliation |
| Motion for oral argument / leave to file sur-reply | Iyoha: argument/reply mischaracterized record; oral argument would help identify issues; sur-reply needed to address reply | AOC: no new issues raised in reply; full briefing adequate for decision | Court: Denied — no need for oral argument; no truly new matters in reply warranting a sur-reply |
| Spoliation / adverse inference from missing documents | Iyoha: missing scoring matrix, draft vacancy posting, justification memo warrant adverse inferences | AOC: plaintiff cannot prove documents existed or were destroyed in bad faith; panelist score sheets and notes exist | Court: Denied adverse inference — plaintiff didn’t show bad faith or that missing docs were material to pretext given other record evidence |
Key Cases Cited
- Spark v. Catholic Univ. of Am., 510 F.2d 1277 (D.C. Cir. 1975) (court has discretion to deny oral argument on summary judgment)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for disparate-treatment claims)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standards and credibility/inference rules)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (movant’s summary judgment burden)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (nonmovant must show more than metaphysical doubt)
- Holcomb v. Powell, 433 F.3d 889 (D.C. Cir. 2006) (types of evidence to show pretext)
- Salazar v. Wash. Metro. Area Transit Auth., 401 F.3d 504 (D.C. Cir. 2005) (when an employer’s atypical involvement in selection can support inference of pretext)
- Murray v. Gilmore, 406 F.3d 708 (D.C. Cir. 2005) (hiring within same protected class cuts against inference of discrimination)