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Maldonado v. Loglogic

July 14, 2009

AMY MALDONADO, PLAINTIFF,
v.
LOGLOGIC, INC., DEFENDANT.



The opinion of the court was delivered by: Royce C. Lamberth, Chief Judge

MEMORANDUM OPINION

This matter comes before the Court on defendant's Motion [40] for Summary Judgment. In sum, defendant LogLogic, Inc. ("LogLogic" or "defendant") terminated plaintiff Amy Maldonado ("Maldonado" or "plaintiff") from her employment at LogLogic. Maldonado now brings three*fn1 causes of action as a result of this discharge:

(1) that she was discriminated against because of her sex in violation of Title VII upon being terminated after announcing her pregnancy; (2) breach of contract; and (3) breach of the implied covenant of good faith and fair dealing. (Pl.'s Second Am. Compl., ¶ 25-53.)

Upon consideration of the defendant's motion, plaintiff's opposition, defendant's reply brief, the applicable law, and the entire record herein, the Court concludes that defendant's motion shall be granted. The Court's reasoning is set forth below.

LEGAL STANDARD

Summary judgment is appropriate when "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Fed. R. Civ. P. 56(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986); Mills v. Winter, 540 F. Supp. 2d 178, 183 (D.D.C. 2008) (Friedman, J.); Diamond v. Atwood, 43 F.3d 1538, 1540 (D.C. Cir. 1995).

To determine if there is any genuine issue of material fact, this Court is to view the record, facts, and all reasonable inferences in the light most favorable to the non-moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157--59 (1970). A genuine issue of material fact is one which could affect the outcome of the litigation. Celotex, 477 U.S. at 322; Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).

DISCUSSION

1. Title VII Sex Discrimination

Plaintiff Maldonado alleges Title VII sex discrimination stemming from her discharge as an employee at LogLogic. Maldonado claims this discharge was prompted by the defendant coming to learn she was pregnant, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000 et seq., as amended by the Civil Rights Act of 1991 ("Title VII") and the Pregnancy Discrimination Act. (Pl.'s Second Am. Compl. 1, ¶ 1.)

This Court will apply the shifting burdens test to determine whether plaintiff's discrimination claim should go to a jury. In the classic McDonnell Douglas test, the first burden is on the plaintiff to establish a prima facie case of discriminatory discharge. McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 1824 (1973).

Defendant argues that Maldonado's claim of discrimination should be dismissed because she cannot make out a prima facie case. Generally, a prima facie case of discriminatory discharge requires a showing that: (1) she is a member of a protected class; (2) she was qualified for the position; (3) she was discharged; and (4) she was replaced by a person of equal or lesser ability who is outside the protected class. St. Mary's Honor Center v. Hicks, 509 U.S. 502, 506-08, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993); Park v. Washington Metro. Area Transit Auth., 892 F.Supp. 5, 10 (D.D.C. 1995), aff'd, 107 F.3d 924 (D.C. Cir. 1996).

However, plaintiff contends that an analysis as to whether she can establish a prima facie case is not appropriate at the summary judgment stage. (Pl.'s Opp'n to Def.'s Mot. for Summ. J., 13.) Indeed,

Lest there be any lingering uncertainty, we state the rule clearly: In a Title VII disparate-treatment suit where an employee has suffered an adverse employment action and an employer has asserted a legitimate, non-discriminatory reason for the decision, the district court need not-and should not-decide ...


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