Shaw Rahman v. Crystal Equation
668 F. App'x 691
| 9th Cir. | 2016Background
- Plaintiff Shaw Rahman, proceeding pro se, sued his employer alleging national origin and religious discrimination, hostile work environment, and retaliation under Title VII; defendants included an individual (Muslin) who resided in Illinois.
- The district court granted summary judgment for defendants and dismissed the individual defendant for lack of personal jurisdiction; Rahman appealed.
- Rahman also moved for recusal of the district judge and for an extension of discovery; both motions were denied by the district court and challenged on appeal.
- Rahman asserted additional claims for breach of contract and violations of the Thirteenth Amendment; the district court rejected these claims.
- The Ninth Circuit heard the appeal de novo and issued a written opinion affirming the district court on all challenged rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hostile work environment (Title VII) | Rahman argued he was harassed because of his national origin and religion | Defendants argued conduct did not meet Title VII hostile-environment standards | Affirmed — Rahman failed to raise a genuine dispute that harassment was based on protected traits or met the legal standard |
| Discrimination (national origin & religion) | Rahman contended adverse employment actions were motivated by religion and origin | Defendants maintained adverse actions were not taken for those protected reasons | Affirmed — no genuine dispute that adverse actions were taken because of religion or origin |
| Retaliation (Title VII) | Rahman claimed he engaged in protected activity and was terminated in retaliation | Defendants argued Rahman did not engage in protected activity before termination | Affirmed — Rahman failed to show he engaged in protected activity prior to termination |
| Personal jurisdiction over Muslin | Rahman argued the Illinois defendant could be sued in Washington | Defendants argued Muslin lacked minimum contacts with Washington | Affirmed dismissal — Muslin lacked requisite minimum contacts for personal jurisdiction |
Key Cases Cited
- Pavoni v. Chrysler Grp., LLC, 789 F.3d 1095 (9th Cir. 2015) (standard of review for appellate review of summary judgment)
- Vasquez v. County of Los Angeles, 349 F.3d 634 (9th Cir. 2004) (elements for hostile work environment claim under Title VII)
- Aragon v. Republic Silver State Disposal, 292 F.3d 654 (9th Cir. 2002) (prima facie elements for Title VII discrimination)
- Stegall v. Citadel Broad. Co., 350 F.3d 1061 (9th Cir. 2004) (elements of retaliation claim under Title VII)
- Wash. Shoe Co. v. A-Z Sporting Goods Inc., 704 F.3d 668 (9th Cir. 2012) (factors for evaluating personal jurisdiction)
- Liteky v. United States, 510 U.S. 540 (U.S. 1994) (recusal standards and when judicial rulings weigh for bias claims)
- Jorgensen v. Cassiday, 320 F.3d 906 (9th Cir. 2003) (district court's discretion over pretrial scheduling and discovery)
- Padgett v. Wright, 587 F.3d 983 (9th Cir. 2009) (appellate rule declining to consider arguments not raised in opening brief)