Bell v. Carson

CourtDistrict Court, District of Columbia
DecidedJune 12, 2025
DocketCivil Action No. 2020-2209
StatusPublished

This text of Bell v. Carson (Bell v. Carson) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bell v. Carson, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

VENETIA D. BELL,

Plaintiff,

v. Case No. 1:20-cv-2209 (CRC)

SCOTT TURNER,

Defendant.

MEMORANDUM OPINION AND ORDER

When workplace tensions arise, it can be difficult to separate ordinary friction from

unlawful discrimination. This case presents precisely that challenge. Venetia Bell, a former

senior attorney with the Office of Legal Counsel at the Department of Housing and Urban

Development’s (“HUD”) Office of Inspector General, claims that, after years of stellar

performance, her work life soured under new leadership due to discrimination and retaliation.

Bell brings Title VII claims alleging that she was (1) denied credit hours, (2) issued a letter of

reprimand, and (3) given a lower annual performance evaluation, either because of her race or

sex or in retaliation for protected equal employment opportunity (“EEO”) activity. HUD now

moves for summary judgment. Because Bell has failed to create a genuine dispute of fact over

whether discrimination or retaliation motivated any of these alleged actions, the Court will grant

HUD’s motion and dismiss the case.

I. Background

A. Factual Background

Ms. Bell joined the Office of Legal Counsel in HUD’s Office of Inspector General

(“OIG”) as a senior attorney in June 2014. ECF No. 33-21 (“Pl.’s Statement of Genuine Issues”) ¶ 1. She worked there until her retirement in February 2020. Id. During that time, Bell was the

only African American attorney in the office. ECF 14 (“Am. Compl.”) ¶ 8.

Bell’s early tenure was marked by apparent success. She received multiple “excellent”

and “outstanding” performance evaluations and was praised for her professionalism and

collaboration. Id. Bell also served in a supervisory role during a period of office expansion. Id.

But, as Bell describes it, things changed when new leadership arrived. In February 2017, Maura

Malone, a white female attorney, was promoted to Deputy Counsel and became Bell’s immediate

supervisor. Id. ¶ 9. According to Bell, Malone immediately adopted a hostile attitude toward her

and “engaged in a campaign to harass her and discredit her work as an attorney at the OIG

because she was an African American woman.” Id. Bell further alleges that Malone treated

white male attorneys with more professionalism and courtesy than her. See id. Bell’s complaint

points to several incidents during the summer and fall of 2017:

• In a mid-year performance review, Malone “falsely” accused Bell of being hostile to another attorney. Id. ¶ 9(a).

• Malone denied Bell’s request for credit hours in July 2017, despite having approved a similar request weeks earlier. Id. ¶ 9(c); see also Pl.’s Statement of Genuine Issues ¶¶ 3–5. Credit hours allow employees who work beyond their standard schedule to earn time off. ECF 31-1 (Def.’s Statement of Undisputed Material Facts (“Def.’s SUMF”)) ¶ 4.

• Malone issued repeated reminders to Bell about submitting assignments even when, according to Bell, the work had already been submitted. Am. Compl. ¶ 9(d).

• Despite knowing that Bell was preparing for a Merit Systems Protection Board hearing, Malone required her to attend approximately six hours of staff meetings in one week. Id. ¶ 9(e). By contrast, Bell claims Malone accommodated a white male attorney with an upcoming trial by adjusting his schedule. Id.

• Malone once treated Bell in a “nakedly hostile” and “condescending” manner in front of colleagues and, on another occasion, spoke to her in an “outright abusive” tone. Id. ¶¶ 9(f)–(g). Bell contends that Malone never treated white male attorneys this way. Id. ¶ 9(g).

2 Following these incidents, in late September 2017, Bell complained to OIG human

resources officials about Malone’s behavior. Id. ¶ 10. The office conducted what Bell describes

as an “abbreviated” and “incomplete” investigation. Id. Although Bell believes the inquiry

supported her concerns, no corrective action was taken. Id.

Shortly thereafter, Bell initiated an informal EEO complaint with HUD’s civil rights

office. Id. Bell asserts that Malone learned of her EEO complaint in October and received a

copy on November 17, 2017. Id. A senior agency official, Brian Pattinson, was appointed to

investigate Bell’s complaint. Id. He met with Malone on November 20, 2017, to discuss the

allegations. Id.

Four days later, Malone issued Bell a formal letter of reprimand for “inappropriate

behavior.” See id. ¶ 11; Def.’s SUMF ¶ 17. The reprimand was authorized by Malone’s

supervisor, Acting Deputy Inspector General Jeremy Kirkland. Am. Compl. ¶ 11. In the letter,

Malone critiqued Bell for her unwillingness to “comply with management requests,” her

“hostility,” and her “refusal to participate.” Def.’s Ex. 5 (“Letter of Reprimand”), ECF 31-2 at

63–65 (page numbers designated by CM/ECF). Specifically, Malone pointed to an email

exchange in which she asked Bell to participate in a meeting later that day. Id. at 64. Bell

responded that she had planned to take a late lunch and exercise and then independently emailed

the client to propose rescheduling. See id. And, when Malone insisted the meeting proceed as

scheduled, Bell questioned why she was only just being informed and what her role in the

meeting would be. Id.

In March 2018, Malone switched positions and ceased serving as Bell’s supervisor. Am.

Compl. ¶ 12. Athena Jones, who had overseen the earlier HR inquiry, assumed the role. Id.

About a week later, Malone reissued the reprimand as a counseling memorandum. Id.

3 According to Bell, Malone entered her office unannounced and insisted that she sign the

document. Id.

Bell claims that she asked both Jones and Kirkland to intervene to stop what she

described as “continued bullying and abusive behavior,” but they took no action. Id. ¶ 13. In

October 2019, the EEOC issued a notice of hearing on Bell’s complaint, which she had since

upgraded to a formal complaint. Id. ¶ 14.

Soon after the hearing was scheduled, Jones informed Bell that she would receive a “fully

successful” performance rating for the 2018–2019 period—her lowest rating to date. Id. ¶ 15.

The lower rating allegedly made Bell ineligible for a performance award. Id. Bell claims that

the written evaluation included positive feedback inconsistent with the rating, and that Jones

justified the score in a later conversation by citing complaints Bell made about management and

her colleagues. Id. The agency counters that the rating was based on Bell’s repeated comments

that she would do the bare minimum to get by and performance that lived up to this promise, as

well as Bell’s hostile attitude toward coworkers. ECF 31 (“Mot. Summ. J.”) at 14–15. Bell then

filed a second informal complaint, followed by another formal EEO complaint in January 2020,

alleging retaliation for her prior protected activity. Am. Compl. ¶¶ 2, 16.

B. Procedural History

Bell filed this lawsuit in August 2020, raising claims of discrimination and retaliation

under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e–16, et seq. See ECF 1

(Compl.) ¶¶ 17–20.1 Bell amended her complaint a year later and added allegations of a hostile

1 Bell named as Defendant then-Secretary of HUD Benjamin Carson in his official capacity.

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