This Littler Lightbulb highlights some of the more significant employment law developments in the federal courts of appeal in the last month.

Fourth Circuit Dismisses White Employee’s Race, Gender, and Retaliation Claims

Barnhill v. Pamela Bondi, __ F.4th __ (4th Cir. May 15, 2025) involved claims by a white Department of Justice Drug Enforcement Administration (DEA) supervisor that she was discriminated against because of her race and retaliated against for filing a complaint with the DEA’s EEO office. Following the case’s dismissal by the district court, the plaintiff appealed to the Fourth Circuit. The plaintiff’s claims were based on a management review and five-day suspension following investigation of complaints about her conduct by a subordinate; a temporary duty reassignment to another location; and promotion denials. The Fourth Circuit agreed with the district court that the plaintiff failed to plausibly allege that any of the adverse actions she described were because of her race or gender and dismissed these claims.

The court also concluded that the plaintiff failed to establish a causal connection between her protected activity – her EEO complaint – and her promotion denials and suspension, finding there was a lack of temporal proximity between the protected activity and the adverse actions she complained of. “While there is not a bright-line rule instructing when temporal proximity is sufficient to establish causation, without other evidence of causation,...

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