Mary Chambers v. DC, No. 19-7098 (D.C. Cir. 2022)
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Plaintiff sought numerous transfers to different units in the Office. After these requests were denied, she filed a charge of sex discrimination with the Equal Employment Opportunity Commission, contending that similarly situated male employees had been granted the transfers they requested. She filed a Title VII suit against the District in 2014 alleging unlawful sex discrimination and retaliation.
The district court, applying Brown, granted summary judgment to the District. On rehearing, Plaintiff contends that Brown is facially inconsistent with Title VII. The DC Circuit explained that without any footing in the text of Title VII or Supreme Court precedent, there is no sound basis for maintaining Brown as circuit law. The court held that an employer that transfers an employee or denies an employee’s transfer request because of the employee’s race, color, religion, sex, or national origin violates Title VII by discriminating against the employee with respect to the terms, and conditions, or privileges of employment. The court reasoned that Brown is fundamentally flawed because it “elevated policy concerns . . . over the plain statutory text.” The plain text of section 703(a)(1) contains no requirement that an employee alleging discrimination in the terms or conditions of employment make a separate showing of “objectively tangible harm.”
This opinion or order relates to an opinion or order originally issued on February 19, 2021.
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