Ranowsky v. National Railroad Passenger Corporation, 244 F. Supp. 3d 138

Background

Plaintiff Kathleen Ranowsky, age 62, was Deputy Counsel in Amtrak Office of Inspector General (OIG) from 2002 until termination in November 2014; Inspector General Tom Howard (also 62) was the sole decisionmaker who terminated her citing "loss of confidence."
Termination letter designated the separation as a "reduction in force," enabling a severance offer; Ranowsky declined and instead took early retirement designation.
After termination, Ranowsky applied in 2015 for (1) the OIG Deputy Counsel role (not interviewed; Kevin Winters hired Frank Mazurek) and (2) a temporary transactional attorney role in Amtrak Law (William Herrmann declined to interview her based on prior interactions).
Ranowsky sued under the D.C. Human Rights Act alleging age and sex discrimination, wrongful termination, failure to rehire, and that Howard and Terry Gilmore aided and abetted discrimination/retaliation; defendants removed the case to federal court and moved for summary judgment.
The court applied McDonnell Douglas burden-shifting and summary judgment standards and concluded Amtrak offered legitimate, non-discriminatory reasons (loss of confidence; prior interactions) that Ranowsky failed to rebut as pretext.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination (Nov 2014) was age discrimination under DCHRA	Ranowsky argues termination was motivated by age; cited replacement by younger attorneys and questions about retirement	Howard asserts he lost confidence in Ranowsky's legal reliability and performance; decisionmaker consistent about reason	Court held insufficient evidence of age discrimination; employer offered legitimate reason and plaintiff failed to show pretext
Whether termination (Nov 2014) was gender discrimination under DCHRA	Ranowsky argues replacement by a male deputy indicates sex bias	Defendants note partial replacement by a female and that male supervisor was also terminated same day; decisionmaker male and same age	Court held insufficient evidence of sex discrimination; plaintiff failed to show pretext
Whether refusal to rehire in 2015 was discrimination or retaliation	Ranowsky contends not being interviewed/hired was due to age/sex and retaliation after her EEOC charge	Defendants justify not interviewing based on prior termination/loss of confidence and hiring managers' personal assessments that she would not fit	Court held defendants entitled to summary judgment on refusal-to-hire claims; plaintiff failed to show discrimination or causal link for retaliation
Whether Howard and Gilmore can be held individually liable for aiding and abetting	Ranowsky alleges they aided/abetted discriminatory/retaliatory conduct	Defendants argue individual liability depends on employer liability; employer did not engage in unlawful conduct	Court held aiding-and-abetting claims fail as a matter of law because the employer's substantive claims failed

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standards)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine dispute and inferences at summary judgment)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
United States Postal Service Bd. of Governors v. Aikens, 460 U.S. 711 (prima facie proof becomes irrelevant once employer provides legitimate reason)
Vatel v. Alliance of Auto. Mfrs., 627 F.3d 1245 (D.C. Cir. 2011) (DCHRA claims analyzed like federal discrimination law)
Allen v. Johnson, 795 F.3d 34 (D.C. Cir. 2015) (retaliation elements and pretext analysis)
Baloch v. Kempthorne, 550 F.3d 1191 (D.C. Cir. 2008) (plaintiff must discredit employer's explanation)
Gaujacq v. EDF, Inc., 601 F.3d 565 (D.C. Cir. 2010) (individual aiding-and-abetting liability depends on employer's unlawful conduct)