Court of Appeals Affirms Summary Judgment for Defendants on Age Discrimination Claim Brought Under DCHRA
On May 10, 2012, the District of Columbia Court of Appeals decided Cain v. Reinoso, No. 11-CV-249, slip op. (D.C. May 10, 2012) in which it considered an age discrimination claim brought under the District of Columbia Human Rights Act (“DCHRA”). The plaintiff in this case was terminated from her employment, at the age of 62, by a Deputy Mayor of the District of Columbia who allegedly terminated her due to her age. Id. at 1-2. She then brought an age discrimination claim under the DCHRA against the Deputy Mayor and the District of Columbia. Id. The trial court granted summary judgment for the defendants. Id. at 2. On appeal, the Court assumed for the sake of argument that the plaintiff had presented sufficient evidence to establish a prima facie case of discrimination under the DCHRA. Id. at 9. Specifically, it assumed that her evidence was sufficient to show “(1) that she was a member of a protected class, (2) that she was qualified for the job from which she was terminated, (3) that her termination occurred despite her employment qualifications, and (4) that a substantial factor in her termination was her membership in the protected class.” Id. at 4 (internal brackets and quotation marks omitted). The Court then proceeded to consider whether the defendants had “articulated a ‘legitimate, nondiscriminatory basis’ for terminating [the plaintiff’s] employment.” Id. at 9. The Court reviewed the defendants’ evidence regarding an internal reorganization and downsizing, an evaluation of the plaintiff’s work performance, and the superiority of another employee, and concluded that the defendants had presented “a legitimate, nondiscriminatory explanation” for the Deputy Mayor’s decision to terminate her employment. Id. at 19. The Court then considered whether the plaintiff could overcome that explanation by showing that it was “pretextual.” Id. at 19-29. The Court concluded that the plaintiff had not presented any specific evidence showing that the explanation was pretextual. Id. Notably, the plaintiff had acknowledged during her deposition that neither the Deputy Mayor nor his chief of staff had “ever made any age-related or discriminatory remark to her.” Id. at 13. Accordingly, the Court affirmed the trial court’s grant of summary judgment for the defendants. Id. at 29-30.