Laughlin v. Metro. Wash. Airports Auth. - 149 F.3d 253 (4th Cir. 1998)

Rule:

To establish a prima facie case of retaliation under Title VII of the Civil Rights Act of 1964, an employee must prove three elements: (1) that she engaged in protected activity, (2) that an adverse employment action was taken against her, and (3) that there was a causal link between the protected activity and the adverse employment action.

Facts:

Karen Laughlin, a secretary to the Washington National Airport manager, Augustus Melton, discovered a copy of the unsigned written warning on Melton’s desk addressed to William Rankin, the supervisor of Kathy LaSauce, the employee who filed a complaint against Rankin. Laughlin concluded that Melton was engaging in a coverup to prevent LaSauce from having adequate access to relevant documents for a future lawsuit. As a result of these suspicions, Laughlin removed the documents, photocopied them, and replaced the originals on her boss's desk. She sent the copies to LaSauce with a note stating that she thought LaSauce might find them interesting. Laughlin's removal and copying of the documents was discovered in 1996 during a deposition in a civil suit filed by LaSauce. Laughlin was terminated as a result of removing the documents. As a result of her termination, Laughlin filed a complaint with the EEOC on April 18, 1996, alleging retaliatory dismissal. The district court granted summary judgment in favor of the employer. LaSauce appealed. 

Issue:

Did the employer illegally terminate LaSauce upon discovering that the latter removed the documents in question from her boss’ desk? 

Answer:

No.

Conclusion:

The appellate court held that to prevail, the former employee was required to prove that her activity was protected under Title VII of the act. In this case, the former employee's actions constituted opposition activity, which required the court to balance the act's purpose of protecting persons engaging reasonably in activities opposing discrimination against Congress's desire not to tie employers' hands in the objective control of personnel. The court held that the former employee's opposition activity was not protected where the former employer's interest in maintaining confidentiality of documents outweighed the former employee's interest in providing the documents to another former employee. Furthermore, the court held that the treatment of the former employer's motion to dismiss as one for summary judgment was not an abuse of discretion.