Williams v. Johnson
870 F. Supp. 2d 158
D.D.C.2012Background
- Plaintiff Christina Williams, former Chief of the APRA Center of Research Evaluation and Grants, led ACIS software implementation for DC Health.
- On February 14, 2006, Williams testified about ACIS at a DC Council Committee on Health oversight hearing.
- Plaintiff contends Johnson and his Chief of Staff subjected her to harassment and retaliation after the hearing.
- She resigned in June 2007 after accepting a position with the U.S. Public Health Service.
- Williams sued the District under the DC-WPA asserting ten retaliation claims, including constructive discharge and hostile work environment, and a November 2011 trial yielded a $300,000 verdict in her favor.
- Defendant moved for judgment as a matter of law or a new trial under Rule 50(b), which the Court denied, allowing judgment on the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams made a protected disclosure | Williams reasonably believed her Council testimony disclosed gross mismanagement | Testimony did not disclose a protected matter | Yes; sufficient evidence supported protected disclosure |
| Whether Williams was constructively discharged | Working conditions were intolerable and led to resignation | Resignation occurred after conditions not intolerable | Yes; sufficient evidence supported constructive discharge |
Key Cases Cited
- Scott v. District of Columbia, 101 F.3d 748 (D.C. Cir. 1996) (standard for sufficiency of evidence; court cannot reweigh credibility)
- Mendoza v. Borden, Inc., 195 F.3d 1238 (11th Cir. 1999) (trustworthiness of working conditions in constructive-discharge analysis)
- Wallace v. City of San Diego, 479 F.3d 616 (9th Cir. 2007) (test for intolerable working conditions supporting constructive discharge)
- Arthur Young & Co. v. Sutherland, 631 A.2d 354 (D.C. 1993) (definition of constructive discharge—intolerable conditions)