William Albro v. Richard Spencer, 20-15981

Plaintiff William Albro, a non‑LDS Navy employee at the China Lake research facility, sued the United States Navy under Title VII for religious discrimination and retaliation.
Coworker Ephraim Washburn repeatedly tried to recruit Albro to the LDS Church, baptized Albro’s wife, and later became Albro’s direct supervisor.
After Washburn became supervisor, Albro alleges Washburn subjected him to hostile conduct that culminated in a Navy investigation, suspension, and a planned reassignment directed by Washburn.
Albro complained to a manager, HR, and the Navy’s EEO office about preferential treatment of LDS members and objected to Washburn supervising him; he then filed a formal Title VII complaint.
The district court dismissed Albro’s First Amended Complaint under Federal Rule of Civil Procedure 12(b)(6).
The Ninth Circuit reviewed de novo, affirmed dismissal of the retaliation claim, reversed dismissal of the discriminatory‑treatment claim, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discriminatory treatment (Title VII)	Albro alleges Washburn’s long history of recruitment, later supervisory role, and Washburn’s direction of investigation, suspension, and reassignment show discrimination for non‑affiliation with LDS	Navy contends Albro’s assertions that Washburn caused the adverse actions are conclusory and insufficient to plead the fourth McDonnell‑Douglas element	Court: Allegations plausible; not merely conclusory — reversal of dismissal and claim may proceed
Retaliation (Title VII)	Albro says he engaged in protected activity by complaining to management, HR, and EEO, and that adverse actions followed	Navy argues there is no plausible causal link because decisionmakers who suspended/reassigned him were not alleged to know of his complaints	Court: Dismissal affirmed — Albro failed to plead that the adverse actors knew of his protected complaints, so no plausible but‑for causation

Prodanova v. H.C. Wainwright & Co., LLC, 993 F.3d 1097 (9th Cir. 2021) (standard of review — de novo review of Rule 12(b)(6) dismissal)
Peterson v. Hewlett‑Packard Co., 358 F.3d 599 (9th Cir. 2004) (elements for pleading discriminatory treatment under Title VII)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (distinguishing legal conclusions and threadbare recitals from factual allegations)
Freitag v. Ayers, 468 F.3d 528 (9th Cir. 2006) (elements for Title VII retaliation claim)
Westendorf v. W. Coast Contractors of Nev., Inc., 712 F.3d 417 (9th Cir. 2013) (retaliation requires protected activity be the but‑for cause of the adverse action)