Livia Ujhelyi v. Tom Vilsack
695 F. App'x 285
| 9th Cir. | 2017Background
- Plaintiff Livia Ujhelyi, proceeding pro se, sued her employer (USDA) alleging Title VII retaliation and other employment-related grievances after job reassignment, intimidation of her husband, a disputed debt, and ultimately termination.
- The district court dismissed some claims for lack of subject-matter jurisdiction and granted summary judgment to the defendant on the retaliation claims and related motions; Ujhelyi appealed.
- The court held it had no jurisdiction over allegations outside the scope of the EEOC investigation (reassigned duties and husband’s intimidation).
- The court granted summary judgment on the termination-based retaliation claim because Ujhelyi failed to show a causal (but-for) connection between her husband’s protected activity and her firing.
- The court also granted summary judgment on the debt-related retaliation claim because Ujhelyi did not present specific and substantial evidence that the employer’s non-discriminatory reasons were pretextual.
- The district court’s denials of discovery and sanctions motions, and its award of costs to the defendant, were affirmed as not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction over reassignment and husband-intimidation claims | Those allegations are part of the discrimination/retaliation claim and should proceed | EEOC charge did not encompass those allegations; district court lacks jurisdiction | Dismissed for lack of jurisdiction (claims fell outside EEOC investigation scope) |
| Retaliation claim based on termination | Termination was retaliatory due to husband’s protected activity | No causal link; termination not caused by husband’s activity | Summary judgment for defendant; plaintiff failed to show but-for causation |
| Retaliation claim re: denial of reconsideration of debt | Denial was retaliatory; employer’s reasons were pretext | Employer gave legitimate, non-discriminatory reasons for denying reconsideration | Summary judgment for defendant; plaintiff failed to show pretext with specific, substantial evidence |
| Discovery and sanctions denials; costs award | Denial prejudiced case; sanctions warranted; costs improper | District court acted within discretion; costs proper for prevailing party | Denials affirmed; no abuse of discretion; costs award affirmed |
Key Cases Cited
- Freeman v. Oakland Unified Sch. Dist., 291 F.3d 632 (9th Cir. 2002) (district court jurisdiction limited to matters within scope of EEOC investigation)
- Arrington v. Wong, 237 F.3d 1066 (9th Cir. 2001) (standard of review for Rule 12(b)(1) dismissals)
- Vasquez v. County of Los Angeles, 349 F.3d 634 (9th Cir. 2003) (summary judgment standard review)
- Coons v. Sec’y of the U.S. Dep’t of the Treasury, 383 F.3d 879 (9th Cir. 2004) (elements of Title VII retaliation claim)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 133 S. Ct. 2517 (2013) (Title VII retaliation requires but-for causation)
- Stegall v. Citadel Broad. Co., 350 F.3d 1061 (9th Cir. 2003) (pretext requires specific and substantial circumstantial evidence)
- Hallett v. Morgan, 296 F.3d 732 (9th Cir. 2002) (district court discretion in discovery rulings; standard of review)
- Holgate v. Baldwin, 425 F.3d 671 (9th Cir. 2005) (standard of review for denial of sanctions)
- Fink v. Gomez, 239 F.3d 989 (9th Cir. 2001) (district court’s inherent sanctioning power)
- Ass’n of Mexican-Am. Educators v. California, 231 F.3d 572 (9th Cir. 2000) (strong presumption in favor of awarding costs to prevailing party)