Molovinsky v. Fair Employment Council of Greater Washington, Inc.

11(с) All one section factors should members of the concur in this be Board applied. report and recommendation.

Although Respondent we believe suspended year,

should be one we do not that the vague

believe and indefinite condi

tions for reinstatement ordered imposed by

Minnesota Court should be Appeals.

District of In Columbia Court stead, MOLOVINSKY, Respondent’s Executive reinstatement should be Gale S. t/a Suite, Appellant, proving conditioned on his fitness in the man normally required jurisdiction. ner in this (D.C. Roundtree, re See In 503 A.2d 1215 FAIR EMPLOYMENT COUNCIL OF 1985). Since we are of the view that it would WASHINGTON, INC., GREATER difficult, if impossible, be not for a District of al., Appellees. et Respondent’s supervise Columbia monitor to Minnesota, practice in are not recоm No. 93-CV-1142. mending probation that he placed be after Appeals. District Columbia Court of expiration of his suspension. Argued We do believe our recommended sanc June “substantially tion would result different Decided Oct. 11(c)(4). XI, discipline” under Rule As pointed out the District Columbia Appeals Coury, in In re

Court A.2d (D.C.1987), 11(c)(4) section will invoked sanction, foreign

“where the whatever its

form, effectively significantly is either heavi lighter impose

er which we

the same misconduct.” Our recommended significantly

sanction would not be either lighter imposed

heavier or the sanction than Chadwick,

in Minnesota. See In re also (D.C.1991); ‍‌‌‌‌‌‌‌‌‌​‌‌‌‌​​​​​‌​‌‌​‌‌​​‌‌‌‌​‌‌​​​​​‌​‌​​​​​‍Slosberg, and In re (D.C.1994).

A.2d 1329

Recommendation Board recommends that the District Appeals Cоurt of enter an order

of Columbia Respondent period

suspending for a of one on a

year, reinstatement to be conditioned

showing by Respondent that he fit to is jurisdiction. in this

practice law again

Respondent’s attention once should XI, requirements called to the Rule

§ 14(g). ON RESPON-

BOARD PROFESSIONAL

SIBILITY McKay

By: James C. McKay

James C. 11,1996

Dated: March (5) that

ages; the trial court erred allow- ing impeached him to be of a with evidence (6) conviction; that the erred in court permitting counsel appellees’ to strike (7) juror; male court white its refusing erred in to reread entire instruc- punitive damages in to a response tion on second, jury to note. We decline reach the third, appel- arguments and fourth preservе appel- lant failed to those issues for reject arguments his late review. We other Molovinsky, pro Gale S. se. judgment. affirm the and Sellers, DC, Joseph Washington, M. with Buchanan, Erickson, E. whom Avis John R. brief, Paul D. and Manca were spring Maria Henderson appellees. responded by appellant’s to an advertisement Suite, Washington in company, Executive TERRY, FERREN, Before and opportunities pay- Post which career offered STEADMAN, Judges. Associate $25,000 $100,000. ing from to Ms. appointment and made an PER CURIAM: Henderson called аppellant Molovinsky, for an interview with Henderson, Appellees Hodg- Maria Laura owner, Executive offices Suite es, Baker, Employment Karen and the Fair Washington. downtown On the scheduled Washington, Inc. Council Greater date, waiting to while Ms. Henderson was (“FEC”), filed this sex discrimination suit Molovinsky, receptionist meet with Mr. against appellant Molovinsky. In their com- gave explaining her a brochure the various plaint, plaintiffs alleged three female services offered Executive Suite. when, advertisement, respоnse they an to promoted personal enhancement of brochure employment sought appellant, advice from he skills, strategic and and educational advice them, sexually harassed violation of consultation, and referral services. Rights Human District Columbia (1992) §§ During to dis- 1-2501 1-2557 interview Act”). (“DCHRA” ways with Henderson various to “the FEC cussed Ms. improve appellant’s conduct her résumé. He also said that violated DCHRA forcing purpose by using bypass personnel frustrated his she could and the FEC’s services directly departments it tо divert from established and make contact resources its major compa- programs appellant’s an effort to address the chief executive officers However, he that he jury appellant misconduct. A found liable nies. when told her appellees. charged all of and for his ser- and awarded between $1500 $300 vices, explained appellant Ms. that she Before this court makes several Henderson (1) assignments point, He them. At that accord- error. contends could afford testimony, Mоlovinsky’s (Hodges ing to Henderson’s the FEC and the individual testers Baker) “very he rude changed: an ac- became and lacked demeanor “sugar vulgar” against him and were therefore not enti- and and made references tion (2) daddies,” “prostitution.” damages; “pimps,” that the and Molo- tled to evidence just if permit jury vinsky his told to find that Henderson she would insufficient Suite,” life,” “give part [her] little company, met the statuto- bit he “Executive (3) “employment agency”; give greatest her “the deal of life.” ry [her] definition an permit Ms. asked him whаt the evidence insufficient to When Henderson meant, and a “dis- lowered his voice jury to find that conduct was sex, said, “through criminatory practice” meaning of told her that within the “Sex.” He (4) DCHRA; way financial taking insuf- care of the that the evidence was that’s justify problem.” an award dam- ficient Ms. reported Molovinsky’s Henderson explained purpose pro- that the is to FEC’s Washington duct to the Lawyers’ Committee equal employment opportunity mote within (“WLC”), Rights for Civil Columbia, which forwarded primary the District of and that its complaint her determining FEC. After goals students, high are to train school that the matter investiga- warranted further identify equal conduct research to barriers tion, designed gender the FEC discrimina- employment opportunities, engage in race testing program arranged for four discrimination, testing to uncover racial pose testers —two men and two women —to participate community outreach and job seekers and visit Executive Suite. public According education. to Ms. Reid’s Each telephoned tester Executivе indi- Suite testimony, Molovinsky’s conduct had frus- vidually arranged appointment for an by forcing purpose trated FEC’s it to Molovinsky. with Mr. pro- divert resources from its established grams to undertake sexual discrimination testers, The two female Hodges Laura and testing. The FEC thus had to incur unex- Baker, experiences Karen had similar to that pected counseling costs for victims of sex they Ms. Henderson. When informed Mo- discrimination, educating public about lovinsky they that could not his afford ser- unacceptable the kinds of conduct thаt con- vices, provide he offered to free services in harassment, stituted sexual placing and for exchange being “sugar daddy” his their emphasis community additional on women, out-reach “pimp.” All including three Ms. public and Henderson, education.1 testified at trial that Molovin- sky’s eye contact sexually suggestive and solely defense consisted gestures hand had made them uncomforta- testimony. propositioning his own He denied ble, they humiliated, had felt and that the female testers and Ms. Henderson and they lasting negаtive impressions had suggesting denied of them that he their encounter with him. exchange would waive his fees in for sex. Agatha Farngalo, a indepen- woman who might He admitted that he have used the dently had made a complaint similar “sugar daddy,” term but he insisted that if he WLC, testified that when she visited Molo- did, merely part it was of a standard sales vinsky in visit, to Ms. Henderson’s pitch asking people that included who lacked Molovinsky had asked her also if she had a they funds whether had “a favorite uncle or “sugar daddy” and offered to waive his feеs somebody” ‍‌‌‌‌‌‌‌‌‌​‌‌‌‌​​​​​‌​‌‌​‌‌​​‌‌‌‌​‌‌​​​​​‌​‌​​​​​‍to take care of them. sex, in exchange for suggesting even at one jury against returned a verdict Molo- point they go nearby a room a vinsky damages and awarded to each of the Farngalo hotel. Ms. also testified to the plaintiffs. jury gave To Ms. Henderson the lingering emotional effects and humiliation $17,000 $10,- in compensatory damages and experienced. she had punitive damages; 000 in to Ms. Baker and testimony testers, of the two male $5,000 Hodges, compensatory Ms. each in Tuckett, Pospisil John quite Ernest $10,000 each in dam- They different. said they that when in- FEC, $22,000 ages; compensa- and to the .in Molovinsky they formed Mr. could not tory damages. services, Molovinsky merely afford told get job, them money, earn some II Pospisil come back later. and Tuckett also represented testified that had Molovinsky urges us to reverse Executive only employment Suite as “the ground that the individual testers and the agency in college graduates.” town for standing bring FEC lacked an action Reid, Chairperson against Inez Smith him. hold that both the individu- FEC, standing testified about the harm that Molovin- al testers and the FEC had sky’s conduct caused to the FEC. Ms. Reid claims under the DCHRA. parties stipulated vertising budget proxy publication that Executive Suite’s as a for the $12,000. advertising budget yearly necessary publication Ms. Reid costs to counteract the ef- Molovinsky’s discriminatory practices. testified that the FEC used Executive Suite’s ad- fects of quoted phrase us Standing

A. Tester the use of the indicates to Individual standing under the DCHRA is co-exten- Employ relies on Fair standing under Article III. sive Washington, Inc. v. ment Council Greater Marketing Corp., U.S.App. D.C. BMC plaintiff’s statutory of a (1994), Violation proposition F.3d for the “actual rights may itself constitute an do not have individual testers injury” sufficient to confer Article BMC, however, threatened to sue under the DCHRA. Realty standing. Corp. v. III Havens Cole persuasive has little value on the tester man, 1114, 1121, standing issue. The court did not ad U.S. S.Ct. BMC (1982). provision dress the anti-discrimination In Havens the 71 L.Ed.2d Su closely most resembles the DCHRA terms preme Court held that a tester who prohibited practices relief: and available statutory right of her to truthful violation Rights Title 1964 Civil VII housing Article satisfied the III information Rights amended the 1991 Civil Act.2 See 374, 102 requirement injury fact. Id. at (1994); §§ 42 U.S.C. 2000e-l to 2000e-17 plaintiff at 1121. The testers Sutherland, Young Arthur & Co. statutory alleged a violation of their (D.C.1993). n. Thus 361 & 17 we turn right As to be free from sexual harassment.3 language of the DCHRA itself in decid Havens, injury rights their ing standing tester issue. Furthermore, the stat personal. direct and injury utory accompanying exist violation “[a]ny person The DCHRA allows in respect to the testers’ intentions without claiming by discriminatory be aggrieved” to initiating “That the tester the encounters. practice against to an action court fully may approached [appellant] ex have l-2556(a). offending § party. D.C.Code discrimination], [experience pecting sex to nearly Supreme The Court construed any [accepting of without intention an Rights language of the Act of identical Civil referral], negate employment does not (“any person 1968 who claims to have been meaning simple injury of of fact within injured”) standing to to the full extent confer Id.; Evers see also v. [the DCHRA].” рermits. that Article III of the Constitution 204, 178, 180, 202, Dwyer, 79 S.Ct. 3 358 U.S. Metropolitan v. Insurance Trafficante Life (1958) (fact plaintiff 222 board Co., 209, L.Ed.2d 205, 93 34 409 U.S. pur for racially segregated the sole (1972); ed bus Gray Greyhound L.Ed.2d 415 see challenge East, instituting litigation seg to pose of U.S.App. D.C. Lines (1976) Thus regation significant”). “not (construing F.2d Title VII DCHRA, in this case had stand hold that the testers to confer language, identical III). alleged of their ing of Al to sue for the violation standing to the limits Article III, rights the DCHRA.4 though this court is not bound Article under (b), Rights § example, part of Civil Act amended Title VII to 42 U.S.C. 2000e-2 2.For damages past provide tions, remedy Rights as a for viola- states: for the Civil At the time does DCHRA. employment practice unlawful It shall an BMC, however, not autho- events in Title VII did employment agency an to fail refuse for damages, testers rize an award of employment, discrimi- refer for otherwise (Article III) satisfy constitutional failed against, any individual because of nate race, standing enjoin requirements sue to future for color, sex, religion, origin.... or national they did not show a likelihood violations because DCHRA, l-2512(a), pаrt of the subject they of future viola- would states: BMC, U.S.App. supra, D.C. tions. discriminatory practice be an It shall unlawful F.3d at 1272. acts, any following wholly or to do discriminatory partially based for a reason opinion, part explain III As we shall color, race, origin, religion, upon national any challenge to has waived any ... individual: sex [or] alleged. applicability to the facts DCHRA SjS >¡5 ‡ Hi sfc acting (2) plaintiff employment, in this case were for testers To fail or refuse refer program classify employment, any ausрices established under the of an or refer for or to individual, discrimination, employment the di- combatting to discriminate or otherwise that Mr. rectors of which had reason believe against, individual.... Organizational B. Standing supports finding Molovinsky’s discrim- inatory pur- conduct frustrated the FEC’s argues also that the FEC pose promoting equal employment oppor- standing lacks compensatory to recover dam tunity. Ms. Reid testified that the FEC had ages it “injury cannot show in fact.”5 counseling to increase its of sex discrimina- BMC, Relying again on he asserts that the tion victims and its educational efforts FEC’s gender- diversion of funds to test for negative message, order to counteract based discrimination was “self-inflicted” and conduct, public by BMC, sent to the injury thus not an at all. See 409-410, U.S.App. acceptable sex discrimination is D.C. at behav- 28 F.3d at 1276- standing Courts are ior. Thus the FEC divided as to whether the established its compensatory diversion of resources “injury constitutes an sue for frustra- in fact” standing which confers plaintiff. on a tion purpose.7 of its BMC, Compare supra, Villаge Bell wood, Dwivedi, (7th 895 F.2d Ill Cir.1990). We need not decide whether it Molovinsky raises three not, claims of however, does or does because a differ First, evidentiary insufficiency. argues he theory supports ent standing FEC’s sue that the evidence was insufficient ‍‌‌‌‌‌‌‌‌‌​‌‌‌‌​​​​​‌​‌‌​‌‌​​‌‌‌‌​‌‌​​​​​‌​‌​​​​​‍to establish this case. statutory Executive Suite met the defini Supreme Havens, Court held in su “employment Second, an agency.” pra, housing organization that a fair argues support that the evidence could have to sue if the defendant’s dis finding that his actions awere “dis criminаtory practices “perceptibly impaired” criminatory practice” meaning within the organization’s ability pur achieve its Third, the DCHRA. he contends that pose improving equal housing opportunity justify evidence was insufficient to an award through counseling and referral services. punitive damages. of None of these claims “Such concrete and injury demonstrable properly preserved appeal, was however. organization’s activities —with the conse Molovinsky moved for a directed verdict at quent drain organization’s on the re plaintiffs’ the close of the on the “em standing, sources” —conferred the Court ployment agency” “discriminatory prac Havens, 379, said. 455 U.S. at 102 S.Ct. at grounds, tice” but he 1124; accord, BMC, did not renew that supra, U.S.App. 307 motion or move for a directed 410, 1277; verdict8 at the D.C. at Spann 28 F.3d at v. close of all Village, strictly the evidence. This court 216, Colonial Inc. U.S.App. 283 D.C. 221, 24, 29, Super. 50, denied, gov construes Ct. Civ. R. 899 F.2d which cert. 498 U.S. 980, 111 erns such motions. The 112 failure make a L.Ed.2d 521 (1990). Molovinsky that, “precludes Rule party concedes 50 motion a analo from gously, standing questioning the FEC has appeal sufficiency to sue for on purpose.6 Best, frustration of its Record evidence University evidence.” Howard v. Molovinsky might (D.C.1991) (defendant committing have been a dis- A.2d who fails to criminatory practice. express opinion no request special estopped a verdict is from com- availability to the of a cause of action under the plaining appeal on that the verdict is defective similarly DCHRAto testers not situated. valid). thеory liability when at least one is event, any compensatory damages the amount of repre- FEC does not claim aas sought purpose that the FEC for frustration of its interest, parties sentative of the real but as a compensatory damages exceeded the amount of plaintiff right. in its own awarded, and thus the entire award to the FEC may damages resulting be attributed to from Molovinsky states in his brief that "to the ex- purpose. frustration of its perceptibly impaired pro- tent FEC in its grams effective, programs ... аnd its are rendered less damages.” it is entitled to appropri- 8.A motion for directed verdict was the ate motion to make at the time this case was Although the record does not reflect the basis tried in 1993. Under a 1995 amendment to Rule FEC, jury's for the award of to the judgment it is now called a motion "for as a request special failure to verdict matter of law.” enables us to affirm the award on the frustration purpose theory. Cappadona, See Nimetz (D.C.1988) (citations omitted). banc) (“Congress prescribed A.2d has сertain Although are relevant to a fact finder’s precision” “technical is not re- convictions moving verdict, are quired King credibility determination. We bound for a directed decision.”). Kidd, (D.C.1993) Congress’ policy 14-305 (citing Section Best), present in its form was enacted in 1970 as failure make motion is at all part of the District of Columbia Court Reor- just more than There- technical defect. 91-358, fore, ganization Pub.L. No. 84 Stat. we conclude that Mr. (1970). legislative history right appeal challenge waived his on that statute demonstrates thаt it ex- sufficiency of the evidence that Executive designed pressly “eliminat[e] the discre- “employment agency” engaged Suite was an judge trial limit prevent “discriminatory practice.” fortiori, in a A impeachment by proof a witness of a right challenge also waived the suffi- viction criminal [a] offense....” ciency supporting of the evidence the award H.R..Rep. 91-907, Cong., No. 91st 2d damages, Sess. which he never raised (1970).11 Molovinsky’s claim Thus of error all before the trial court.9 14-305(b). light

must fail of section IV Molovinsky also contends that women, jury composition final black six Molovinsky asserts the trial woman, consti one white and one black man erroneously court im allowed him tuted racial and sex discrimination” “clear cross-examination, peached, on with his Although his and denied him a fair trial. conspiracy conviction of to counterfeit or al clear, argument entirely is not currency ter of the United He ar States. challenging by appel- use appears to prejudicial gues that the effect of that evi challеnge to peremptory lees’ of one counsel outweighed probative dence its value and was juror.. Upon prospective strike a white male solely jury. argu used to inflame the This removal, Molovinsky’sobjection juror’s 14-305(b) (1995), ignores ment the court said: provides which that “evidence that the wit is sub- Okay. don’t think there ness been convicted criminal [certain] your allegations at all to either with stance offensefs] shall be if admitted offered way in respect panel, which added), (emphasis long cross-exаmination” so selected, panel certainly nothing as the witness’ release from confinement or respect discriminatory with use to the expiration parole, probation, the sen peremptory challenges. tence, later, more whichever was occurred no years ten trial male than before the date. There was one white 14-305(b)(2)(B).10 lawyer, § simply The struck there D.C.Code admis who was a and discretionary. a evidence is was one strike utilized. There’s not even sion such States, See, e.g., Langley prima v. A.2d facie such that I even United 515 would (D.C.1986) (“a 729, require no 735 trial court has further of Ms. Buchanan whether discriminatory based preclude discretion to use convictions or not her intent was impeachment”); upon going v. I’m not gender Dorman bias.... for United (en States, (D.C.1984) 455, inquiry on 491 A.2d have further this record. statement, change involving dishonesty Appellant’s pro this or false se status does not 9. might 305(b)(1), requirement result. Whatever the situation a that was also sat- 14— pro litigants, a matter that need not other address se isfied here. here, Mr. is a law school graduate the and a former member of bar. recognized a few 11.Such discretion had been comply no to excuse his failure to see reason States, years v. earlier Luck United with the rule. 151, (1965), U.S.App. which D.C. 348 F.2d 763 14- had construed an earlier version of section ten-year limit was met here. Molovin- legislative history makes clear sky’s the took sentence ended in trial Luck, Congress specifically intended to overrule 1993, only eight years place later. rejecting "absolutely rule as unwork- the Luck addition, requires, The statute the H.R.Rep. 91-907, supra, at able.” No. felony for an offense viction be either a respect composition jury asking, With a of the after the sent note “Does itself, panel a jury there are lot of women on need to future harm in order find panel. allega- I don’t think naked damages?” punitive response award claim, tion itself protec- even raises the question, said: the court claim, any requires tion other claim that point you’re get- I think I understand the court to take action at all. at, ting ques- and the answer to the short Supreme Court Batson v. Ken tion is no. You must determine whether tucky, U.S. punitive damages upon to award based (1986), three-part L.Ed.2d 69 a fashioned test conduct in defendant’s actual this case. party evaluate claims a that another Molovinsky argues that the court’s “short party right per or her exercised his inadequate prejudicial answer” be emptory challenge discriminatory in a man high jury cause it did not remind the First, party claiming ner. a Batson vio degree necessary punitive of malice to award prima must showing lation make a facie damages. argue, however, He does not purposeful discrimination. Once that has the trial court’s statement was inaccurate.13 done, the been burden shifts to the other respond The trial discretion court had party to nondiscriminatory establish a reason jury’s degree note in the detail shown, strike. If such reason a is court believed warranted. Robinson party claiming burden shifts back to the (D.C. States, United 642 A.2d violation, who show must then that the strike 1994). The note rеvealed no confusion about was motivated intentional discrimination. justify mental state that an award 96-98, 106 Id. S.Ct. at 1722-24. damages. Even if a ex detailed us, On the before record we are planation might been more have favorable court, satisfied that the trial proper after a Molovinsky, we find no abuse of discre inquiry, Batson in concluding did not err give decision “short answer” Molovinsky had prima failed to show facie specific question. to a single peremptory that counsel’s strike was discriminatory on a Appellees based reason. V only juror, lawyer, struck one white male reasons, For foregoing judgment failed to “come forward with the trial court is just alone,” facts, not numbers make a prima showing of discrimination. Lit facie Affirmed. (D.C. States, tle United 1992) (citations omitted). “This court ... TERRY, Judge, concurring: Associate give must deference to both trial court’s join fully opinion. I in the court’s findings write ruling of fact and its ultimate however, separately, possible to note a defect prima, whether the defendant satisfied the legislature, Batsоn, the DCHRA our (citing facie burden.” which Id. at 1723). Columbia, 97, 106 might Council of the supra, 476 District U.S. at S.Ct. at appropriately find error here.12 address. no Finally, Molovinsky Molovinsky Mr. that the evidence contends that contends trial prove court erred it failed to was insufficient to that his conduct when reread was punitive damages proscribed entire “discriminatory practice” by its instruction on Molovinsky allegations ‍‌‌‌‌‌‌‌‌‌​‌‌‌‌​​​​​‌​‌‌​‌‌​​‌‌‌‌​‌‌​​​​​‌​‌​​​​​‍alleged totally 12. makes two other about trial. These comments are undoc- jury. juror umented, however, First he that the one male asserts Molovinsky has not elderly throughout slept the trial. This any shown influence” "extraneous that would by the claim is contradicted court’s own state- judgment. warrant See reversal of the Tanner elderly gentleman, ment on the record: "He's an States, United 483 U.S. S.Ct. eyes, and did see him so he does close his do (1987). 97 L.Ed.2d 90 occasionally, [to] that but I watched him see if he sleep. sleep.” ever went to He never went to Accordingly, express opinion 13. no haveWe no reason to conclude that this state- explanation. accuracy of the trial court's Second, Molovinsky ment incorrect. makes juror claims about off the record comments after ground. provides on this Neverthe- DCHRA. Act that it is an a directed verdict less, one, troubling and the discriminatory ... fail the issue is a practice to “unlawful statutory ought it any language is not as clear as employment to refer for ... refuse individual, Molovinsky exposed be. what to discriminate Mr. otherwise may significant loophole § 1- in the statute. against, be a individual.” D.C.Code added). 2512(a)(2) that such as (emphasis Molovinsky ar- If the Council believes conduct Molovinsky is or should be action- gues he not “fail or refuse” to refer that Mr. that did DCHRA, may it wish employment, nor did able under women testers Indeed, legislative action to make clear better services the men. sider offer such learning inability pay, he DCHRA covers behavior. after of their equally He refused his services men. argues the conduct

further

appellees, proven, if is not even actionable type it is of discrimination

prohibited by Appellees con- the statute. hand,

tend, phrase “or other gives applica- the statute broad

otherwise” relationships, employment tion to cover all CERRONI, Respondent. Joseph re A. including the type of sexual harassment engaged. Molovinsky which of the District A Member of the Bar Appeals. of Columbia Court no be question There is crude, boorish, utterly unac havior was 93-BG-1673, Nos. 95-BG-1407. ceptable. compelling argument, He makes Appeals. of Columbia Court of District however, type is not of conduct prohibited by Although sexual the DCHRA. Sept. Submitted discriminatory is actionable as a harassment Decided Oct. VII, limited practice under Title it has been workplace in the that either situations conditioning employ concrete involve the favors or create

ment benefits on sexual See working

hostile environment. Meritor Vinson, 57, 106

Savings Bank 477 U.S. (1986). no 91 L.Ed.2d 49 Since relationship

employment existed between testers, these neither of and the case, no is met here. I have found

conditions any, suggesting that appellees

nor cited have con should be phrase ‍‌‌‌‌‌‌‌‌‌​‌‌‌‌​​​​​‌​‌‌​‌‌​​‌‌‌‌​‌‌​​​​​‌​‌​​​​​‍otherwise” “or such as that

strued so as to conduct ambit of within the hand, I

DCHRA. On the other narrowly a interpret statute

reluctant legisla “undoubtedly intended” broadly eliminate the

ture “to read in. discrimination

many proscribed forms of District_” Co Dean v. District of (D.C.1995).

lumbia, need my colleagues that agree suffi- whether evidence decide discriminatory practice

cient to establish preserve failed to by moving for appellate review issue

Case Details

Case Name: Molovinsky v. Fair Employment Council of Greater Washington, Inc.

Court Name: District of Columbia Court of Appeals

Date Published: Oct 3, 1996

Citation: 683 A.2d 142

Docket Number: 93-CV-1142

Court Abbreviation: D.C.