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Garland's Digest
on employment discrimination law
online since 1997

 

National Origin Discrimination Pregnancy Discrimination Race
Discrimination
Religious
Discrimination
Sex
Discrimination
Sexual
Harassment

 

 

 

Disclaimer: The case on which this summary is based may no longer be current law. Also, if the case was decided on summary judgment, the court recited the "facts" in the light most favorable to the non-movant, which may not be the true facts.

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Court finds that harassment by supervisor and that supervisor's successor are part of the same hostile work environment even though the harassment by each supervisor took different forms. 

Vickers v. Powell, 493 F.3d 186 (D.C. Cir. July 6, 2007)

Facts: This is Title VII race and sex discrimination and retaliation action plus an appeal of a decision from the Merit Systems Protection Board.

Cynthia Vickers, an African-American woman, worked for the Federal Deposit Insurance Corporation (FDIC) as a criminal investigator until her dismissal in 2001. Vickers had a strained relationship with her supervisor, Dana Bedwell (a male).

On October 31, 2000, they got into an argument. Vickers quit. On November 2, Bedwell sent Vickers a letter that gave his account of the argument and granted her four hours of administrative leave for the time she left work on October 31. The letter also warned that if she did not return by November 6, he would begin termination proceedings. She returned on November 6 and requested six months of leave without pay to resolve the "mental, emotional, and physical anguish" caused by her employment. Her request was granted. In November, she filed an EEOC charge, but the record does not provide any information about the charge.

For the next five months, she was treated for severe depression. Her physician said she could return to work on May 1, 2001. She was required by the FDIC to submit to a medical examination, which she did. However, on advice of counsel, she refused to execute two medical release forms because they lacked sufficient safeguards to protect her privacy.

On April 18, 2001, Thomas McDade (who had replaced Bedwell after he retired in March) sent Vickers a letter demanding that she execute the medical forms. She again refused to sign either form. Samuel Holland, Assistant Inspector General for Investigations, made the decision to fire Vickers effective December 14, 2001.

Vickers appealed her dismissal to the Merit Systems Protection Board (MSPB). Before the MSPB, the employer must demonstrate that its reasons for firing the civil servant are supported by a preponderance of the evidence and that the penalty imposed was reasonable. The employee must prove any affirmative defense by a preponderance of the evidence. An administrative law judge (ALJ) upheld Vickers' termination. The ALJ faulted her for not signing one of the two medical release forms. She then appealed to the district court.

District court: The district court granted summary judgment for the FDIC on all claims.

Appeal: With respect to the MSPB decision, the court faults the MSPB for requiring Vickers to sign the one medical form and the court remands to the district court with instructions to further remand back to the MSPB to determine whether any other allegations constitute an independent basis for firing Vickers. [Editor's Note: We do not summarize MSPB decisions, so that is why there is little detail.]

With respect to the retaliation claim, Vickers cannot show that she was terminated based on her EEO complaints. The evidence only shows she was terminated for refusing to sign two medical forms that the decisionmaker thought she was required to sign in order to return to work.

With respect to her discrimination claim, she alleges that she was subjected to two adverse employment actions: (1) unfair performance appraisals and (2) termination. The court finds no evidence of unfair performance appraisals and her termination claim fails for the same reasons her retaliation claim failed.

The important issue in this case is the hostile work environment claim. She alleges thirteen incidents of harassment. Most of the incidents were allegedly perpetrated by her supervisor, Dana Bedwell, or his predecessor, Mike Mitchell. Those alleged incidents are as follows:

1. In 1992 she "was ridiculed by her supervisor [Mike Mitchell] because she attended the Women in Federal Law Enforcement Conference ("WIFLE") in Washington, D.C." Vickers, 2005 WL 3207775, at *9.

2. She "was subject to unwanted and continuing conversations about her [supervisor Mitchell's] divorce and sexual dysfunction" around 1993-1994. Id.

3. In 1995 or early 1996 she "was asked to assist her manager [Mitchell] in going to the restroom by holding his genitals for him." Id.

4. In 1996 Mitchell "forced [her] to listen to sexist remarks about a female coworker, including comments that this co-worker's 'legs flew open' at the sight of a photograph of her abusive husband." Id.

5. Vickers "was shocked when her supervisor [Mitchell] tricked her into picking up a troll-like doll designed so that a large penis fell from under the shirt when she picked it up" in 1995. Id.

6. In 1996 she "was singled out for rude, condescending and often accusatory comments from [Bedwell] who showed no position than he." Id.

7. In 1998 Bedwell "repeatedly subjected her to intrusive and embarrassing inquiries about personal and medical privacy for no reason other than curiosity, including inquiries of other female employees regarding her medical condition." Id. After objecting to these inquiries, she was accused of being "hypersensitive." Id.

8. She "was subjected to unjustly reduced performance rating[s], most recently on her October 2000 performance evaluation. When she objected to the ratings given her, and therefore refused to sign the Performance Plan, she was subjected to angry threats from [Bedwell]." Id. at *10.

9. In 1999 Vickers "was subjected to sexist comments in the work place, including a statement by her supervisor to the Atlanta Regional Agent staff, which at this point was about 12 (twelve) white men and Ms. Vickers to the effect, 'hey, we're all men here.'" Id.

10. She "was subjected to constant derogatory comments made towards women and minorities," including a comment in October 2000 by an instructor employed by the Federal Law Enforcement Training Center "that a baton is a good weapon to use, but depending on the circumstances a gun is a better weapon because it eliminates problems, 'like the Rodney King case.'" Id.

11. In 1998 Vickers "was subjected to racial profiling jokes including a comment that a white male could enter their building unchallenged because 'he didn't fit the profile.'" Id.

12. In 1998 she overheard insulting remarks from behind a closed door regarding "affirmative action when an African-American was selected for a position and her white coworkers suggested that he had been selected only because of his race." Id.

13. Vickers "was singled out for a requirement to provide inordinate amounts of medical information to support requests for leave." Id.

A federal employee must report discrimination to an EEO counselor within forty-five days of the alleged conduct. Vickers did not contact an EEO counselor until November 9, 2000, which would appear to bar any incidents before September 25, 2000. The district court erred in finding that the three alleged incidents that took place within the filing period must, by themselves, make out a claim for a hostile work environment before a court can consider whether the earlier acts are part of the same hostile work environment.

The closer question is whether the alleged harassment by Bedwell is part of the same actionable hostile work environment practice perpetrated by Bedwell's predecessor, Mitchell. Following the teachings of Morgan, the court explains that it "need not consider an alleged incident if it 'had no relation to the [other] acts, or for some other reason, such as certain intervening action by the employer, was no longer part of the same hostile work environment claim."

The district court determined that the acts perpetrated by Mitchell (which were sexual in nature) were not part of the same hostile work environment allegedly perpetrated by Bedwell (whose acts were not sexual in nature). The D.C. Circuit disagrees

that the Mitchell allegations were so different in kind that, as a matter of law, we can conclude that they were not part of the same hostile work environment. The line between Mitchell creating a hostile environment through sexual conduct and his deputy-turned successor Bedwell perpetuating the environment by condoning the same is not so well-defined to say that the Mitchell and Bedwell acts have "no relation" as required in Morgan.

The court then goes on to explain:

   The Mitchell incidents can therefore be severed from the Bedwell incidents only if we accord conclusive significance to the change in management. But routine personnel actions such as Mitchell's retirement and Bedwell's promotion cannot be the type of "intervening action[s] by the employer" that would sever the earlier incidents from the more recent incidents constituting Vickers' hostile environment claim. Id. Although we can easily imagine circumstances in which a change in managers might affect a hostile work environment claim, we see nothing in the record that shows that Bedwell's succession was in any way intended to address the environment created by Mitchell's alleged improprieties.

Therefore, the court holds that all of the alleged incidents of harassment can be considered. The court reverses the grant of summary judgment as to the hostile work environment claim and remands for further proceedings consistent with this opinion.

 



 

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