Turner v. Enzler
236 F. Supp. 3d 121
| D.D.C. | 2017Background
- Turner, an African American woman over 40, was hired as a Community Support Specialist at Catholic Charities in January 2014; employment was at-will and subject to a 90-day probationary period.
- On April 8, 2014, a 15-year-old non-verbal participant (K.S.) was found asleep on a classroom floor; Turner was assigned responsibility for that child and was placed on administrative leave pending a Quality Assurance neglect investigation.
- Investigator Sequaya Tasker concluded the neglect allegation was substantiated, citing evidence that Turner left K.S. unattended; additional reports suggested the child had sometimes arrived from the program in an unclean condition.
- Human Resources reviewed the investigation and, in May 2014, terminated Turner for violating the agency’s Abuse and Neglect policy; Turner's requests for reinstatement were denied.
- Turner sued for race and age discrimination (Title VII and ADEA), arguing the neglect finding was false and that other, younger or non-Black staff who committed similar misconduct were treated more favorably.
- The district court considered whether Catholic Charities provided legitimate, nondiscriminatory reasons for termination and whether Turner produced evidence showing those reasons were pretext for discrimination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Turner proved race discrimination under Title VII | Turner contends she was falsely accused and that younger/white coworkers were not disciplined similarly | Catholic Charities argues it terminated Turner for substantiated neglect after a reasonable investigation | Court held Turner produced no evidence of discriminatory animus; summary judgment for defendant |
| Whether Turner proved age discrimination under ADEA | Turner asserts age was a motivating factor in discipline and termination | Employer maintains legitimate, nondiscriminatory reason (policy violation) and that ADEA requires but‑for causation | Court held Turner failed to show but‑for causation or pretext; summary judgment for defendant |
| Whether comparators are similarly situated | Turner points to Kim Jorden (white, similar age) who allegedly remained employed after an incident | Defendant shows no meaningful evidence that the incidents and circumstances were comparable | Court found plaintiff did not establish similarly situated comparator; comparison fails as a matter of law |
| Whether the employer’s investigation/reason was pretextual | Turner disputes findings, claims other staff agreed to supervise or had ulterior motives | Defendant argues its investigation was thorough, findings reasonable, and HR honestly believed the result | Court concluded the investigation and belief were reasonable; plaintiff’s disagreement insufficient to show pretext |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for indirect‑evidence discrimination cases and burden‑shifting)
- Brady v. Office of the Sergeant at Arms, 520 F.3d 490 (D.C. Cir. 2008) (court examines whether employer honestly and reasonably believed its justification)
- Gross v. FBL Financial Services, Inc., 557 U.S. 167 (2009) (ADEA requires but‑for causation)
- DeJesus v. WP Co. LLC, 841 F.3d 527 (D.C. Cir. 2016) (motivating‑factor standard under Title VII)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard and materiality)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burdens for movant and nonmovant)
