Joseph Anoruo v. Robert A. McDonald, 670 F. App'x 571

Plaintiff Joseph Chidi Anoruo, proceeding pro se, sued under Title VII alleging national-origin discrimination and retaliation after being denied promotion.
District court granted summary judgment for the defendant; Anoruo appealed.
District court struck Anoruo’s surreply for failing to seek leave under local rules and denied several discovery and postjudgment motions (motion to compel performance appraisal, sanctions for missing deposition, motions for reconsideration, and postjudgment leave to amend).
On the discrimination claim, the employer offered a legitimate, nondiscriminatory reason for not promoting Anoruo; the court found no specific and substantial evidence of pretext.
On the retaliation claim, the court found no genuine issue of material fact that the protected activity was causally connected to the promotion decision (timing and lack of causal link).
Anoruo raised additional arguments on appeal that the panel declined to consider where not raised in the opening brief or raised for first time on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of promotion was discriminatory under Title VII	Anoruo argued denial was based on national origin	Employer proffered legitimate, non‑discriminatory reason for promotion decision	Court: No — Anoruo failed to show pretext; summary judgment affirmed
Whether denial of promotion was retaliatory	Anoruo argued he had a pending discrimination claim and was denied promotion in retaliation	Employer argued no causal link between protected activity and promotion decision	Court: No causal link shown; summary judgment affirmed
Whether district court abused discretion by striking surreply	Anoruo argued surreply should be considered	Employer argued local rules require leave; surreply untimely	Court: No abuse — strike proper for failure to seek leave
Whether district court abused discretion on discovery, sanctions, and postjudgment motions	Anoruo argued discovery denial, sanctions, and denial of reconsideration/amendment were improper	Court defended rulings as within discretion and supported by rules/precedent	Court: No abuse of discretion on discovery, sanctions, reconsideration, or postjudgment amendment

Pavoni v. Chrysler Grp., LLC, 789 F.3d 1095 (9th Cir.) (standard of review: de novo for summary judgment)
Vasquez v. County of Los Angeles, 349 F.3d 634 (9th Cir.) (pretext evidence must be specific and substantial in Title VII discrimination claims)
Cornwell v. Electra Cent. Credit Union, 439 F.3d 1018 (9th Cir.) (elements of prima facie retaliation and causal-link analysis)
Hambleton Bros. Lumber Co. v. Balkin Enters., Inc., 397 F.3d 1217 (9th Cir.) (standard of review for district court’s application of local rules)
Delange v. Dutra Constr. Co., Inc., 183 F.3d 916 (9th Cir.) (district court’s broad discretion interpreting local rules)
Hallett v. Morgan, 296 F.3d 732 (9th Cir.) (standard: denial of discovery will not be disturbed absent clear showing of actual and substantial prejudice)
Goodman v. Staples The Office Superstore, LLC, 644 F.3d 817 (9th Cir.) (standard of review for sanctions under Rule 37)
Sch. Dist. No. 1J, Multnomah Cty., Or. v. ACandS, Inc., 5 F.3d 1255 (9th Cir.) (standards and grounds for relief under Rules 59(e) and 60(b))
AE ex rel. Hernandez v. County of Tulare, 666 F.3d 631 (9th Cir.) (standard: leave to amend after judgment requires reopening judgment under Rule 59 or 60)
Lindauer v. Rogers, 91 F.3d 1355 (9th Cir.) (motion to amend after judgment is improper absent reopening judgment)
Padgett v. Wright, 587 F.3d 983 (9th Cir.) (issues not raised in opening brief or raised first on appeal are not considered)