Zhang v. The Energy Authority Inc, 2:22-cv-00694

Yuan Zhang, a Chinese immigrant and mother, was employed by The Energy Authority (TEA) from 2015 to 2019 and was promoted in 2017 before being terminated in August 2019.
Disputes arose about Zhang’s job performance, and a significant incident involving a programming error was noted, but no formal disciplinary action was taken.
Zhang announced her pregnancy and planned maternity leave in September 2018; around the same time, TEA planned and executed a reorganization, impacting her job responsibilities but not her title, salary, or benefits.
After returning from maternity leave in May 2019, she informed TEA of her intent to take additional leave; she was terminated before taking this extra leave, with her duties distributed to other employees, including both Asian and non-Asian colleagues.
Zhang filed suit alleging discrimination (race, national origin, gender), hostile work environment, and retaliation under federal (Title VII) and state (WLAD, WFLA) laws; TEA removed the case to federal court and asserted multiple affirmative defenses.
Both parties moved for summary judgment: Zhang for partial summary judgment on intentional gender discrimination and to strike affirmative defenses, TEA for summary judgment dismissing all claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race/National Origin Discrimination	Zhang is a protected class, was qualified, terminated, replaced by non-Asian	Zhang’s performance was inadequate, her eventual replacement was another Asian, duties were reassigned to mixed group	Summary judgment for TEA; dismissed
Gender Discrimination (Pregnancy)	Discriminatory motive proven by change post-pregnancy, adverse action after leave request	Actions were lawful, due to poor performance, not pregnancy/gender	Material disputes; summary judgment for neither party
Hostile Work Environment	Subjectively felt disparate, abusive treatment	No evidence of objectively abusive environment	Summary judgment for TEA; dismissed
WFLA Retaliation	Terminated after expressing intent to take protected leave	No denial of actual leave, action due to performance	Material disputes; claim survives summary judgment
Affirmative Defenses	Should be stricken as boilerplate	Defenses are factually supported, relevant	Some defenses stricken, others remain

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for summary judgment; what constitutes a genuine issue of material fact)
Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s burden at summary judgment and shifting burdens)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for employment discrimination)
Peterson v. Hewlett-Packard Co., 358 F.3d 599 (prima facie requirements for employment discrimination)
Scott v. Harris, 550 U.S. 372 (limits of self-serving or contradicted evidence on summary judgment)
Passantino v. Johnson & Johnson Consumer Prods., Inc., 212 F.3d 493 (causation in retaliation based on the timing of events)
Wallis v. J.R. Simplot Co., 26 F.3d 885 (threshold for plaintiff’s prima facie employment discrimination case)