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Keywords

plaintiffmotiondiscriminationharassmenthuman rights
motionsummary judgmentdiscriminationmotion for summary judgment

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McFarland v. George Washington University, 935 A.2d 337, 101 Fair Empl.Prac.Cas. (BNA) 1874, 226 Ed. Law Rep. 921

Facts

John T. McFarland, an African-American male, was employed as a marketing manager at The George Washington University (GW). He filed a grievance alleging harassment and discrimination by his male supervisor. After applying for a promotion to the position of CEEP Director, which was ultimately awarded to Mattie Hunter, an African-American woman, McFarland's position was eliminated during a departmental reorganization. He claimed that this action was based on race and gender discrimination, as well as retaliation for his earlier complaints.

Issue

Did the university discriminate against McFarland based on race and gender, and did it retaliate against him for filing a grievance?

Did the university discriminate against McFarland based on race and gender, and did it retaliate against him for filing a grievance?

Rule

Under the District of Columbia Human Rights Act (DCHRA), to establish a prima facie case of discrimination, a plaintiff must demonstrate that they are a member of a protected class, qualified for the position, rejected in favor of another applicant, and that their membership in the protected class was a substantial factor in the employment decision. The same burden-shifting framework from McDonnell Douglas Corp. v. Green applies, where the burden shifts to the employer to provide a legitimate, nondiscriminatory reason for its actions.

In order to survive a motion for summary judgment, [the employee must] establish a prima facie case that [the employer discriminated against him]. If such a showing is made, the burden shifts to the employer to articulate a legitimate basis for [its action]. If the employer articulates a legitimate, nondiscriminatory basis for the [action], the burden shifts back to the employee to demonstrate that the employer's action was pretextual.

Analysis

McFarland failed to establish a prima facie case of discrimination as he did not demonstrate that race or gender was a substantial factor in the decision not to promote him. Both he and the selected candidate were African-American, which undermined his claim of racial discrimination. Additionally, he did not show that he was more qualified than Hunter, who had relevant supervisory experience. The university's reorganization was a legitimate, nondiscriminatory reason for the elimination of his position.

McFarland did not establish a prima facie case of racial discrimination. Most notably, he failed to establish the fourth prong of the prima facie test, that a substantial factor in the employment decision was his membership in the protected class. He offered no direct proof of racial animus, nor did his evidence raise an inference of discriminatory intent. Mattie Hunter, who received the promotion, is a member of the same protected class as Mr. McFarland.

Conclusion

The court affirmed the lower court's decision, concluding that McFarland did not establish a prima facie case of discrimination or retaliation.

The court affirmed the lower court's decision, concluding that McFarland did not establish a prima facie case of discrimination or retaliation.

Who won?

The George Washington University prevailed in this case as the court found that McFarland failed to establish a prima facie case of discrimination or retaliation. The court noted that both McFarland and the individual who received the promotion were members of the same protected class, which weakened his claims. Furthermore, the university provided a legitimate reason for the elimination of his position, which was part of a broader reorganization aimed at addressing financial issues within the department.

The George Washington University prevailed in this case as the court found that McFarland failed to establish a prima facie case of discrimination or retaliation.

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