Bowie v. Maddox, No. 08-5111 (D.C. Cir. 2011)
Annotate this CasePlaintiff ("appellant"), a former official of the District of Columbia Office of the Inspector General ("OIG"), was fired after five years on the job purportedly for poor performance. Appellant sued the OIG and alleged that defendants conspired to deter his testimony in a subordinate's employment discrimination trial and ultimately fired him in retaliation for his refusal to help sabotage his fellow employee. At issue was whether the district court erred in entering judgment in favor of defendants on appellant's 42 U.S.C. 1985(2) conspiracy claim, a related claim under 42 U.S.C. 1986 for failure to prevent the conspiracy, and his First Amendment retaliation claim. After a trial on appellant's Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., retaliation claim, the jury found in favor of defendants. The court vacated the dismissal of appellant's sections 1985(2) and 1986 conspiracy claims because the district court erroneously required an invidious, class-based motive for the alleged conspiracy and because the district court concluded, without support, that Title VII was the exclusive remedy for this type of retaliation. Accordingly, the court vacated these claims and remanded for further proceedings and affirmed in all other respects.
The court issued a subsequent related opinion or order on August 31, 2011.
The court issued a subsequent related opinion or order on August 31, 2011.
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