Singletary v. District of Columbia, No. 02-7138 (D.C. Cir. Dec. 16, 2003)

The D.C. Circuit reversed the District Court’s (Judge Sullivan) decision on the Title VII retaliation claim in this case because the district court failed to consider temporal proximity by only looking at a single, remote event. The Court also reversed the District Court on the harassment claim in reliance on Amtrak v. Morgan which allows consideration of older events under the continuing violation doctrine. Also, the Court reversed the Section 1983 claim for failure to promote because of an improper application of the statute of limitations. Accordingly, the case has been remanded for reconsideration of the evidence. An excerpt regarding causation is as follows:

“Although the court found that there was no other evidence of causation that could make up for the temporal proximity that it thought was absent, Singletary, 225 F. Supp. 2d at 57, this circuit has held that a close temporal relationship may alone establish the required causal connection. And here8 MWELA MONTHLY January 2004 the temporal proximity was quite close: Singletary was denied promotion to the acting supervisor position in June 1993, the month after he filed his appeal with the D.C. Court of Appeals. Whether such proximity was enough in this case is, in the first instance, a question for the finder of fact rather than the appellate court. We therefore remand for the district court to determine whether the close temporal relationship between the 1993 protected activity and the 1993 adverse employment action, in the context of other evidence offered by both the plaintiff and the defendants, persuades the court that the defendants unlawfully retaliated against the plaintiff in violation of Title VII.”

To read the opinion, go to: http://pacer.cadc.us courts.gov/docs/common/opinions/200312/02-7138a.pdf.

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