Ng v. Lahood, 952 F. Supp. 2d 85

Ng, an Asian-American FAA employee, alleges Title VII discrimination (race and national origin) and retaliation arising from mid-2000s unit restructuring and related actions.
Ng served as Technical Support Manager in the Communications Unit, supervising staff in Washington, D.C., while based in Boston.
In 2008, supervisor change coincided with a restructuring that merged two groups, placing Ng under a peer-turned-direct-report (Braese) without reducing Ng’s pay or official title.
Sanchez had recommended SCI-1 for Ng in 2008; Lavey later recommended SCI-2, but Pipes approved the SCI-1 rating, resulting in Ng receiving the highest SCI for 2008.
Ng claims reduced supervisory responsibilities, exclusion from management meetings, and removal from the Vortex Project wall and duties after the restructuring.
Ng’s January 2009 60-day Washington, D.C. assignment on the Vortex Project involved travel around Inauguration Day, with limited work upon arrival and some temporary workload changes; Ng also alleges disparaging remarks about his accent by colleagues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ng suffered an adverse employment action	Ng contends multiple actions qualify as adverse actions under Title VII.	Defendant argues none of the incidents meet the adverse-action standard under Baird; many were non-punitive or temporary.	No adverse employment actions shown; summary judgment for defendant on discrimination claims.
Whether any adverse actions were causally connected to Ng's race/national origin or protected activity	Ng asserts discrimination based on race/origin or retaliation for protected activity.	No evidence ties incidents to race, national origin, or protected activity.	No triable causal link established; defendant granted summary judgment on race/origin and retaliation theories.
Whether the Court should strike the post-discovery declarations for summary judgment	Declarations were filed after discovery closed and contradict prior testimony.	Declarations were properly filed and not clearly contradictory.	Ng's motion to strike denied.

University of Texas Southwestern Medical Center v. Nassar, 133 S. Ct. 2517 (U.S. 2013) (but-for causation standard for retaliation)
Brady v. Office of the Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (two elements for discrimination; magistrate to assess non-discriminatory reason)