Where a civilian employee argued the Army retaliated against him by making a temporary detail permanent after he assisted another employee with her employment complaint, but there were no facts causally connecting the reassignment to the protected activity, and there were legitimate non-discriminatory reasons for the reassignment, the Army prevailed on the claim.
Background
Louis Tutt, a civilian Army employee, contended that he engaged in protected activity by assisting a colleague with her Equal Employment Opportunity complaint, and that defendant retaliated against him by issuing a Management Directed Reassignment, or MDR, that made permanent a temporary detail from the Audit Readiness Directorate to the Human Capital Directorate. Defendant moved for summary judgment of plaintiff’s sole remaining claim, alleging retaliation under Title VII of the Civil Rights Act of 1964.
Prima facie case
Under the McDonnell Douglas framework, a plaintiff must first establish a prima facie case by showing that (1) he “engaged in protected activity”; (2) that his employer took a materially adverse action against him and (3) “that a causal relationship existed between the protected activity and the adverse employment activity.’” The only element of plaintiff’s prima facie case defendant challenged was causation.
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