Lyles v. District of Columbia Government
2014 U.S. Dist. LEXIS 119420
| D.D.C. | 2014Background
- Lyles is a 1994 DMH employee alleging Title VII discrimination, retaliation, and hostile environment with ADA disability claim.
- Miller, a subordinate, sexually harassed Lyles March 2007–August 2008; incidents included touching and explicit gestures.
- Lyles reported harassment to supervisor Parks in June 2007; continued incidents occurred; several supervisors were involved in intermediate responses.
- Lyles filed EEOC complaint June 4, 2008; a July 2008 DMH “Statement of Position” claimed the other two female employees did not validate her report and that she did not report harassment.
- Lyles was reassigned from the Supported Employment Program to Day Services in August 2008 and then to CST in November 2008; she was separated from District employment effective August 1, 2009.
- The court previously denied parts of the District’s summary judgment motion and now denies the District’s renewed motion on hostile environment liability and retaliation, finding genuine issues of material fact remain regarding ability to stop harassment and pretext for transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller’s conduct created a hostile work environment under Title VII | Lyles argues harassment was severe or pervasive and actionable. | District maintains the harassment, though troubling, does not meet the standard given the supervisory dynamics. | Genuine issues of material fact remain; summary judgment denied on this issue. |
| Whether Lyles had the ability to stop the harassment as supervisor over Miller | Lyles acted to stop harassment but asserts in many instances Parks failed to respond. | Lyles’s actions were sufficient or Parks’s role determined responsibility; record unclear. | Genuine issue of material fact exists; summary judgment denied on this issue. |
| Whether the Day Services transfer was pretextual retaliation for EEO activity | Transfer timing with EEOC complaint suggests retaliation; pretext shown by weak rationale. | Transfer due to staff needs; timing not dispositive; but no outright pretext. | Genuine issue of material fact exists; reconsideration denied and summary judgment denied. |
Key Cases Cited
- Davis v. Coastal Int'l Sec., Inc., 275 F.3d 1119 (D.C. Cir. 2002) (standard for hostile environment elements)
- Vance v. Ball State Univ., 133 S. Ct. 2434 (Supreme Court 2013) (supervisor harassment liability framework)
- McGrath v. Clinton, 666 F.3d 1377 (D.C. Cir. 2012) (retaliation elements; causation standard discussed (pre-Nassar))
- Nassar v. Univ. of Texas Sw. Med. Ctr., 133 S. Ct. 2517 (Supreme Court 2013) (but-for causation in retaliation claims)
- Morgan v. Fed. Home Loan Mortg. Corp., 328 F.3d 647 (D.C. Cir. 2003) (standard for causation in Title VII retaliation/discrimination)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden-shifting framework)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (clear-material-fact standard for summary judgment)