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Robinson v. Detroit News, Inc. - 211 F. Supp. 2d 101

Rule:

To prevail on a claim of gender discrimination under the District of Columbia Human Rights Act (DCHRA), the United States District Court for the District of Columbia applies the analytical framework used in Title VII of the Civil Rights Act of 1964, because the DCHRA is substantially similar to Title VII. Therefore, the Title VII prima-facie case analysis established in McDonnell Douglas also applies to suits under the DCHRA.

Facts:

A female executive employee of defendant media company's television station left her former job and accepted the position with the television station under the assumption that the company would provide some form of training to help her conduct transactional business. She was an "at-will" employee. She sued the media company for breach of contract, promissory estoppel, breach of the covenant of good faith, and gender discrimination in violation of the District of Columbia Human Rights Act (DCHRA), alleging that the company promised to train her in transactional business. The media company moved for summary judgment.

Issue:

Did plaintiff former employee make a prima-facie case of gender discrimination against defendant media company?

Answer:

No

Conclusion:

The United States District Court denied defendant media company's motion for summary judgment on the promissory estoppel claim because there was a genuine issue of material fact as to whether plaintiff former employee had an actionable claim for promissory estoppel, having shown the company's promises in three specific incidents. The company argued that even if it did promise, it was unenforceable because it was not specific. This was not dispositive for the purposes of summary judgment, when the question of whether a promise was made still remained in dispute. There was a genuine issue whether the company expected the former employee would rely on its promise. Thus summary judgment was inappropriate. Nevertheless, the Court granted the company's motion for summary judgment on the claims for breach of contract, breach of the covenant of good faith, and gender discrimination. Analyzing the DCHRA claim similarly to a Title VII claim, under the McDonnell-Douglas burden-shifting standard, the court held that because the former employee failed to meet her burden to prove discrimination, or that she was similarly situated to the male executives, she did not make a prima-facie case of gender discrimination.

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