Karl Hampton v. Tom Vilsack, 401 U.S. App. D.C. 472

Hampton, a Black male, worked for USDA's Foreign Agricultural Service since 1987 and faced prior EEO litigation that settled.
He was investigated in 2002 for sexual-materials issues and received a seven-day suspension after an administrative process.
In 2003–2004, Hampton faced another ethics investigation for failing to disclose a financial interest in a company.
In 2005, after hotel-receipt reimbursements, an investigation concluded nine falsified receipts totaling over $1,400 were submitted.
Henwood, the second-line supervisor, recommended termination; the FSGB eventually upheld cause for removal.
Hampton challenged only whether race was a motivating factor; the district court granted summary judgment for the Secretary, which the panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether race was a motivating factor in Hampton’s termination	Hampton argues Miller’s racial animus polluted the decision	Defendant contends the decision was independently based on misconduct	No; independent, non-pretextual grounds supported termination
Whether the district court properly applied the pretext standard at summary judgment	Hampton argues evidence permits a reasonable inference of pretext	USDA shows legitimate, non-discriminatory reasons were relied on	Summary judgment proper; reasons were credible and not pretextual
Whether the deciding official was insulated from the biased subordinate's influence	Hampton asserts Miller influenced Henwood	Henwood conducted independent review and reduced charges as appropriate	Henwood acted independently; no evidence of disqualifying bias by Henwood
Whether Miller’s 2002 remark infected Henwood’s 2006 termination decision	Racial animus from Miller tainted the outcome	Chain of causation broken; Henwood’s independent assessment rejected pretext	Not proven; no causal link shown between Miller’s remark and Henwood’s decision

Brady v. Office of Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (whether the employer’s reason is pretextual must be analyzed with independent review)
Griffin v. Washington Convention Ctr., 142 F.3d 1308 (D.C. Cir. 1998) (subordinate bias relevant where it influences ultimate decision)
Staub v. Proctor Hosp., 131 S. Ct. 1186 (S. Ct. 2011) (employer liable when biased action motivates adverse action via supervisor)
Waterhouse v. District of Columbia, 298 F.3d 989 (D.C. Cir. 2002) (evidence of discrimination may include evidence of discriminatory attitudes)
Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (D.C. Cir. 1998) (en banc; supporting framework for mixed-motive claims)
Desert Palace, Inc. v. Costa, 539 U.S. 90 (S. Ct. 2003) (plaintiff need only show race was a motivating factor for any employment practice)