History
  • No items yet
midpage
Turner v. Enzler
236 F. Supp. 3d 121
| D.D.C. | 2017
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: Turner v. Enzler
Court Name: District Court, District of Columbia
Date Published: Feb 21, 2017
Citation: 236 F. Supp. 3d 121
Docket Number: Civil Action No. 2014-1093
Court Abbreviation: D.D.C.