Maria Melendez v. Board of Ed. for Montgomery Co, 711 F. App'x 685

Maria Melendez, a former employee of the Board of Education of Montgomery County (BEMC), appealed the district court’s grant of summary judgment to BEMC on Title VII claims for sex discrimination, retaliation, and hostile-work-environment harassment.
Melendez proceeded under both direct-evidence and McDonnell Douglas circumstantial-evidence frameworks; she identified Hopkins’ statement that he “did not want women working in the morning” as direct evidence.
Alleged adverse actions: a two-hour schedule change, a negative performance evaluation and placement in a Performance Improvement Process (PIP), and constructive discharge (she also raised unpaid leave on appeal but did not preserve it below).
Melendez pointed to an incident in which a supervisor pushed a trash can at her and to derogatory remarks; she claimed these and other actions created a hostile work environment and were retaliatory after she sent a complaint letter in May 2010.
The district court granted summary judgment to BEMC; the Fourth Circuit reviewed de novo and affirmed, finding Melendez’s evidence legally insufficient to create genuine disputes of material fact.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Direct sex discrimination (direct-evidence route)	Hopkins’ statement about not wanting women in the morning and other remarks show discriminatory motive	Hopkins’ stray remark is isolated and lacks a clear nexus to adverse decisions	Court: remark too attenuated/isolated to be direct evidence; summary judgment affirmed
Discrimination—adverse actions (schedule change; PIP)	Two-hour schedule change and placement in PIP materially altered terms/conditions of employment	Schedule change caused only minor inconvenience; PIP and evaluation alone are not materially adverse	Court: schedule change and PIP not materially adverse; no prima facie shown
Constructive discharge	Workplace conditions (negative evaluations, trash-can incident) were intolerable and motivated by sex/retaliation	Conditions were not objectively intolerable; incidents were isolated and not shown to be motivated by sex or retaliation	Court: conditions not objectively intolerable; constructive discharge fails
Retaliation and hostile-work-environment harassment	May 2010 complaint letter and other protected activity led to adverse actions and harassment	Timing and lack of causal connection negate retaliation; incidents not sufficiently severe/pervasive or shown motivated by sex	Court: retaliation fails (timing/cause); harassment fails (not severe/pervasive and motive not shown)

Jacobs v. N.C. Admin. Office of the Courts, 780 F.3d 562 (4th Cir. 2015) (summary-judgment standard and retaliation analysis)
Hill v. Lockheed Martin Logistics Mgmt., Inc., 354 F.3d 277 (4th Cir. 2004) (direct- and circumstantial-evidence frameworks for Title VII)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
Brinkley v. Harbour Recreation Club, 180 F.3d 598 (4th Cir. 1999) (definition of direct evidence and role of derogatory remarks)
Merritt v. Old Dominion Freight Line, Inc., 601 F.3d 289 (4th Cir. 2010) (limited probative value of stray or isolated remarks)
Goode v. Cent. Va. Legal Aid Soc’y, Inc., 807 F.3d 619 (4th Cir. 2015) (elements of prima facie discrimination case)
James v. Booz-Allen & Hamilton, Inc., 368 F.3d 371 (4th Cir. 2004) (what constitutes an adverse employment action)
Freeman v. Dal-Tile Corp., 750 F.3d 413 (4th Cir. 2014) (elements for constructive discharge)
Nassar v. Univ. of Tex. Sw. Med. Ctr., 133 S. Ct. 2517 (2013) (but-for causation requirement for retaliation)
Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (1998) (motive requirement for Title VII harassment)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993) (severe or pervasive standard for hostile work environment)