Tyler v. District of Columbia Housing Authority
273 F. Supp. 3d 274
| D.D.C. | 2017Background
- James H. Tyler (age 67 at application) applied to DCHA on September 19, 2007 for a Security Officer position that required a high school diploma or equivalent (GED).
- Tyler’s application indicated high school attendance and some college courses but did not affirmatively state he had a diploma or GED or the dates of completion.
- DCHA did not hire Tyler; it treats incomplete applications as ineligible and removed them from the applicant pool.
- Tyler filed an EEOC charge alleging age discrimination; the EEOC declined to pursue the matter after finding he was not selected because he failed to indicate a diploma/GED.
- Tyler filed suit under the Age Discrimination in Employment Act (ADEA). Discovery showed he did not appear for deposition and did not respond to requests for admission; DCHA moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tyler stated a prima facie ADEA failure-to-hire claim | Tyler contends he was qualified (GED/college credits shown) and rejected due to age | DCHA contends Tyler was not qualified because his application did not show a high school diploma/GED and incomplete applications are not processed | Court held Tyler failed to show he was qualified and thus failed to make a prima facie ADEA case; summary judgment for DCHA |
| Whether a failure to hire was motivated by age (but-for causation) | Tyler alleges age discrimination as the reason for non-hire | DCHA points to nondiscriminatory reason (lack of required education); EEOC found no evidence of age discrimination | Court relied on McDonnell Douglas framework and found no genuine dispute of material fact that age was the cause; dismissed claim |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden shifting and proof standards)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (materiality and genuine dispute standards for summary judgment)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (ADEA requires but-for causation)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Teneyck v. Omni Shoreham Hotel, 365 F.3d 1139 (elements of ADEA prima facie failure-to-hire claim)
- O'Connor v. Consol. Coin Caterers Corp., 517 U.S. 308 (limitations on using replacement by outside class as prima facie element)
- Carter v. George Washington Univ., 387 F.3d 872 (failure to prove qualifications defeats prima facie case)
- Laningham v. U.S. Navy, 813 F.2d 1236 (summary judgment evidentiary standards)