US Court of Appeals for D.C. reverses D.C. district court’s dismissal of hostile work environment retaliation claim

On September 15, 2020, the US Court of Appeals for the District of Columbia reversed the D.C. district court’s motion to dismiss the Plaintiff Cassandra Menoken’s Title VII and disability discrimination claims against the Equal Employment Opportunity Commission (EEOC).

Menoken worked as an attorney for the EEOC from 1982 to 2016. Menoken claims that the EEOC violated Title VII by engaging in a multi-year pattern of harassment and hostility against her in retaliation for her filing anti-discrimination and retaliation claims against various federal agencies beginning in 1994. Menoken also alleged that the EEOC’s hostile behavior caused her to seek medical treatment for “depression, acute stress…and…post-traumatic stress disorder.”

As a result of these medical conditions, Menoken sought a reasonable accommodation from the EEOC under the Rehabilitation Act, which requires that federal employers accommodate individuals with disabilities under the same standards as the Americans with Disabilities Act (ADA). The EEOC denied this request. Menoken subsequently claims that this denial constituted disability discrimination. 

The district court dismissed Menoken’s complaints in their entirety for “failure to state a claim” upon which relief can be granted, meaning the claim, or the elements presented as the cause of the action within the claim, is insufficient. However, the US Court of Appeals for the District of Columbia found that the district court erred in dismissing Menoken’s hostile work environment and reasonable accommodation claims and sent the case back to the district court for reconsideration. 

The district judge who granted the motion for dismissal has since retired (Judge Collyer), so it has not yet been decided which judge will take the case once it returns to district court.

If you are experiencing retaliation or disability discrimination, contact us today. We have a dedicated team of attorneys who can help employees determine their rights under the applicable laws, obtain relief, and hold employers accountable.