Vatel v. Alliance of Automobile Manufacturers
393 U.S. App. D.C. 305
| D.C. Cir. | 2011Background
- Karen Vatel was hired as an assistant to the interim president of the AAM in June 2006 and retained when David McCurdy became President and CEO in December 2006.
- Problems in the McCurdy–Vatel working relationship emerged beginning May 2007, with HR regular meetings about McCurdy’s frustration with Vatel’s performance.
- Vatel was fired on November 1, 2007, with McCurdy citing incompatible working styles and unmet expectations for an assistant.
- Vatel sued in DC Superior Court alleging termination due to race and gender under the DC Human Rights Act; defendants removed based on diversity and moved for summary judgment.
- The district court granted summary judgment for McCurdy and AAM; the DC Circuit reviews de novo and affirms the grant of summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McCurdy's stated reason is pretext for discrimination | Vatel argues pretext from fabrication of incompatible styles to mask bias | McCurdy's belief in incompatibility was honest and reasonable | Pretext not shown; summary judgment upheld |
| Whether lack of direct discrimination evidence prevents jury trial | Direct evidence of bias not required if pretext shown | No direct evidence; cannot infer discriminatory motive from absence | No jury issue; summary judgment proper |
| Whether McCurdy's selection of Vatel undermines an inference of discrimination | Selection timing could reflect bias hidden later | Initial selection weakly undermines discrimination claim; focus is on decision to fire | Selection timing not enough to create triable issue |
Key Cases Cited
- Brady v. Office of the Sergeant at Arms, 520 F.3d 490 (D.C.Cir. 2008) (pretext inquiry under DC law)
- Aka v. Washington Hosp. Ctr., 156 F.3d 1284 (D.C.Cir. 1998) (employer- employed perception governs ruling)
- Waterhouse v. District of Columbia, 298 F.3d 989 (D.C.Cir. 2002) (employer’s hiring-before-firing motive undermines discrimination inference)
- George v. Leavitt, 407 F.3d 405 (D.C.Cir. 2005) (reasonable belief in underlying facts supports termination decision)
- Fischbach v. District of Columbia Dep't of Corr., 86 F.3d 1180 (D.C.Cir. 1996) (employer's honest belief standard in discrimination cases)
- Carney v. American University, 151 F.3d 1090 (D.C.Cir. 1998) (factual proffers requiring too much speculation for discrimination inference)
- Vickers v. Powell, 493 F.3d 186 (D.C.Cir. 2007) (limits on speculation about employer motives)
- Hawkins v. PepsiCo, Inc., 203 F.3d 274 (4th Cir. 2000) (perspective of decision maker governs assessment of discrimination)