Lacasse v. Didlake, Inc.
194 F. Supp. 3d 494
E.D. Va.2016Background
- Plaintiff Chantal Lacasse, a supported‑employment Didlake janitor with epilepsy and learning disabilities, alleged that her supervisor Roy Evo sexually assaulted her in a DLA supply closet on August 15, 2013. She reported the incident in August 2013.
- Didlake is a nonprofit employer that had sexual‑harassment policies, provided training, and conducted an internal investigation once the allegation surfaced; it also reported the matter to Adult Protective Services and cooperated with a federal investigation.
- Didlake investigators found no corroborating eyewitnesses, Evo denied the allegations, and evidence established Evo had an alibi; Evo was placed on administrative leave and later removed from the site.
- Lacasse returned to work on paid leave, was given supports (cell phone exception; female partner), and received an increased pay rate after improved productivity.
- Later supervisors issued several disciplinary warnings and a three‑day paid suspension for Lacasse’s repeated workplace misconduct (name‑calling, socializing, spreading rumors). Lacasse resigned voluntarily in May 2014 and sued, asserting tort claims and Title VII/ADA discrimination and retaliation claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Respondeat superior for assault/battery/false imprisonment/IIED | Didlake is liable for Evo’s alleged sexual assault on site | Evo’s acts were personal and outside scope of employment | Court: employer not liable; acts were personal and outside scope of employment (Counts I–IV dismissed) |
| Title VII hostile work environment | Evo’s conduct created a hostile environment; Didlake failed to remediate | Didlake had policy, training, promptly investigated and remedied | Court: Didlake implemented prompt, adequate corrective measures; employer liability barred (Count V dismissed) |
| ADA discrimination / constructive discharge | Lacasse was constructively discharged due to hostile conditions tied to disability | Lacasse suffered no adverse action; she resigned voluntarily and conditions were not objectively intolerable | Court: no adverse action or intolerable conditions shown; ADA discrimination/constructive discharge fails (Count VII dismissed) |
| Retaliation under Title VII and ADA | Lacasse was retaliated against after reporting Evo | No materially adverse employment action; discipline was for Lacasse’s misconduct; no causal link | Court: no adverse action or causal proof; retaliation claims fail (Counts VI & VIII dismissed) |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Meritor Savings Bank v. Vinson, 477 U.S. 57 (Title VII hostile‑work‑environment standard)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination/retaliation)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (but‑for causation for retaliation claims)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (materially adverse action standard for retaliation)
- Plummer v. Center Psychiatrists, Ltd., 252 Va. 233 (employer liability limited to acts within scope of employment)