Snowden v. Zinke

Snowden v. Zinke

Opinion

 [*22]  MEMORANDUM OPINION

Plaintiff Michael Snowden is an African American male who formerly worked as a Sergeant for the United States Park Police ("USPP"). (See Compl., ECF No. 1, ¶¶ 3, 16-17.) On August 25, 2015, Snowden filed the instant complaint under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., alleging that USPP discriminated against him on the basis of race when it demoted him and later terminated his employment. (See Compl. ¶¶ 53-60.) Snowden further alleges that USPP retaliated against him for filing an Equal Employment Opportunity ("EEO") complaint that challenged his demotion. (See id. ¶¶ 62-68.)

Before this Court at present is USPP's Motion to Dismiss or, Alternatively, for Summary Judgment.¹ (See Def.'s Mot. to Dismiss or, Alternatively, for Summ. J. ("Def.'s Mot."), ECF No. 47-2.) USPP argues that Snowden cannot proceed [**2]  with his claims regarding his demotion, as he failed to exhaust available administrative remedies. (See id. at 3.)² USPP also maintains that Snowden's demotion and termination were "effectuated pursuant to the terms of a valid, voluntarily executed contract"—specifically, a Last Chance Agreement—pursuant to which Snowden had waived his rights to challenge any adverse employment action stemming from the agreement. (See id. at 3, 12-13.) Given the existence of this contract, USPP argues that Snowden cannot show that his demotion and termination were the result of discrimination or retaliation, nor can he prove that USPP's asserted non-discriminatory reasons for demoting and terminating him are pretextual. (See id. at 3-4.) In response, Snowden contends that he exhausted his administrative remedies, that the parties' contract does not bar his claims, and that the evidence, when construed in his favor, demonstrates that USPP's explanations for his demotion and [*23]  termination are pretextual. (See Pl.'s Opp'n to Def.'s Mot. to Dismiss or, Alternatively, for Summ. J. ("Pl.'s Opp'n"), ECF No. 48, at 24, 28, 31, 38.)

On November 30, 2020, this Court issued an Order that GRANTED USPP's motion. (See Order, ECF No. 51.) This Memorandum [**3]  Opinion explains the reasons for that Order. In short, and as explained fully below, this Court has concluded that Snowden waived his right to bring a legal action challenging his demotion and termination, pursuant to the terms of the parties' valid contract. The Court has further determined that, even if Snowden had not waived his rights in this regard—and even if the Court assumes that Snowden has exhausted all administrative remedies—no reasonable jury could find that USPP's stated reasons for Snowden's demotion and termination are pretextual. Therefore, USPP is entitled to summary judgment with respect to all of Snowden's claims.

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