Primas v. District of Columbia, 719 F.3d 693

Primas, an African-American MPD commander, faced a two-rank demotion in 2007 during Lanier's MPD reorganization.
Lanier offered Primas a Captain rank; Primas retired due to salary/pension loss and humiliation concerns.
Shortly after, Lanier appointed Westover, a white man, to the same director role at Inspector rank.
Lanier then offered Primas an Inspector-level position, which she rejected as a de facto demotion.
Primas sued the District and Lanier asserting Title VII, ADEA, and DC Human Rights Act discrimination claims.
District court granted summary judgment; Primas moved to unseal confidential discovery records, which the court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is sufficient evidence of pretext for race/sex discrimination	Primas argues Lanier’s timing and Westover’s higher rank show pretext	Lanier asserts the reorganization was a legitimate non-discriminatory business decision	Remanded; summary judgment reversed for trial on discrimination claims
Whether the district court properly denied unsealing records	Public interest requires access; records reveal discriminatory conduct	Confidential discovery materials should remain sealed	Remanded to apply Hubbard factors; sealing decision vacated for explanation

Brady v. Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (discrimination proof framework for pretext”)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court 2000) (pretext evidence may show non-discriminatory reason is false)
Lathram v. Snow, 336 F.3d 1085 (D.C. Cir. 2003) (discriminatory purpose inferred from false employer explanations)
Washington Gas-Light Co. v. Lansden, 172 U.S. 534 (1899) (jury decides among conflicting inferences)
National Children’s Center, Inc., 98 F.3d 1406 (D.C. Cir. 1996) (strong public-access presumption; Hubbard factors guidance)
United States v. Hubbard, 650 F.2d 293 (D.C. Cir. 1980) (six-factor test for sealing confidential records)