Alleged Actions Of Employee's Manager Did Not Constitute Adverse Employment Actions
Harvey L. Patterson, an African-American federal employee in a supervisory position, brought a Title VII action claiming that his immediate supervisor engaged in unlawful racial discrimination against him through her various interventions into Patterson's management of his division at the Environmental Protection Agency (“EPA”). He also claimed that his later transfer to another position within the EPA amounted to unlawful retaliation directed against his filing and pursuit of a discrimination complaint before the EPA's Office of Civil Rights.
The district court granted summary judgment for the defendant. On appeal, the D.C. Circuit affirmed, holding that: (1) the alleged actions of Patterson’s manager, if proven, did not constitute adverse employment actions; and (2) the agency's proffered reasons for transferring Patterson were not pretexts for retaliation.
Patterson v. Johnson
The D.C. Circuit Court of Appeals’ jurisdiction includes federal administrative agencies and the Tax Court.