By Kathleen Kapusta, J.D.
Absent any contrary directive from the D.C. Circuit, the court applied Muldrow and Chambers to the employee’s discrimination claims.
After rejecting the Secretary of State’s attempt to cabin Muldrow and Chambers to private-sector Title VII suits, a federal court in the District of Columbia, declining in part to dismiss the race discrimination claims of a Black state department employee who alleged, among other things, that she was forced to resign from the Blacks in Government (BIG) affinity group, found it premature to conclude, as a matter of law, that being forced to resign from a leadership position of an employee affinity group was not an adverse employment action for Title VII purposes. While the employee sufficiently alleged that some of the other actions, such as an increased workload, constituted an adverse employment action, she failed to establish that they were connected to her race, said the court, dismissing the bulk of her discrimination claims. Her retaliation and hostile work environment claims were also dismissed (Rhone v. Rubio, No. 24-3389 (RC) (D.D.C. Oct. 28, 2025)).
BIG resignation. The employee began working as an EEO specialist with the Department of State’s Office of Civil Rights (OCR) in 2016. In February 2017, she alleged that two supervisors told her she had to resign as VP of BIG because of a policy decision made by OCR leadership, which, she claimed, negatively impacted her career and advancement opportunities. Five...
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