Kumar v. District of Columbia Water & Sewer Authority, 25 A.3d 9

Kumar, of Indian descent, worked at WASA from June 2003 to March 2005 as Manager of Procurement and Material Management, overseeing the water-filter distribution program during a 2004 lead crisis.
Kumar reported a tense relationship with Carter, an African-American supervisor, with alleged instances of Carter downgrading Kumar's performance ratings and using demeaning language.
In 2004, Kumar sought approval to attend an out-of-town training; Ball approved, Carter denied citing a board meeting and rumors of outside employment, though later personal leave at Kumar's expense was approved.
In August 2004 Kumar filed an internal EEO complaint supported by Ball; WASA investigated and found no merit.
In early 2005, as a result of delays in purchasing filters and other issues, WASA’s general manager asked Ball to resign; Kumar resigned on March 15, 2005 after being offered a severance waiver, which he sign-ed then revoked later.
Kumar sued WASA and Carter for negligent or fraudulent misrepresentation (OWBPA-related) and race/national origin discrimination; trial court dismissed misrepresentation evidence and later granted judgment as a matter of law on discrimination claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Misrepresentation claim dismissal on damages	Kumar asserts harm from OWBPA misrepresentation; trial court denied relief.	No damages from misrepresentation; waiver revocation permits no extra remedy.	Dismissal affirmed; no damages shown as a matter of law.
Judgment as a matter of law on discrimination claims	Kumar argues prima facie case and pretext; evidence supports discrimination.	No prima facie case or pretext; legitimate nondiscriminatory reasons established.	Judgment as a matter of law for WASA/Carter affirmed.

Tompkins v. Washington Hosp. Ctr., 433 A.2d 1093 (D.C.1981) (law-of-the-case doctrine; finality requirements)
Guilford Transp. Indus., Inc. v. Wilner, 760 A.2d 580 (D.C.2000) (interlocutory rulings not final; law-of-the-case limitations)
Washington v. Government of D.C., 152 A.2d 191 (D.C.App.1959) (final judgment required for law-of-the-case)
McFarland v. George Washington Univ., 935 A.2d 337 (D.C.2007) (standard for judgment as a matter of law; evidentiary threshold)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S.2000) (burden-shifting framework; pretext analysis under burdens)
Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S.1998) (definition of adverse employment action in discrimination law)
Oubre v. Entergy Operations, Inc., 522 U.S. 422 (U.S.1998) (OWBPA context; employee rights upon severance)