Gulley v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedJuly 15, 2020
DocketCivil Action No. 2018-2607
StatusPublished

This text of Gulley v. District of Columbia (Gulley v. District of Columbia) 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
Gulley v. District of Columbia, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JASON S. GULLEY,

Plaintiff,

v. Case No. 1:18-cv-02607 (TNM)

DISTRICT OF COLUMBIA,

Defendant.

MEMORANDUM OPINION

Jason Gulley joined the D.C. Metropolitan Police Department (“MPD”) in March 2000.

Over the next 16 years, he was promoted twice, ultimately becoming a Lieutenant. But that lofty

rank was short-lived. Within a year, Gulley was demoted back to Sergeant. A few years later,

MPD terminated him altogether.

Gulley, who is Caucasian, sued the District of Columbia for racial discrimination and

retaliation, claiming that MPD favored minority officers in violation of Title VII of the Civil

Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq. Pending here is the District’s motion

for summary judgment.

The District argues that most of Gulley’s allegations are administratively barred. And for

those that remain, the District maintains that it terminated him because of his long history of

disciplinary infractions, not for any discriminatory purpose. Gulley claims that the District’s

explanations are an illegal pretext for its discriminatory intent. Upon careful review of the briefs

and the record, the Court agrees with the District. Gulley’s disciplinary infractions and other

misconduct gave the District ample cause for its actions. As explained more fully below, the Court holds that no reasonable jury could find in Gulley’s favor. The District is entitled to

summary judgment.

I.

MPD hired Jason Gulley as a Police Officer in March 2000. Def.’s Stmt. of Undisputed

Material Facts (“SUMF”) ¶ 1, ECF No. 23-1. In October 2006, he was promoted to Sergeant.

Pl.’s Opp’n at 1, ECF No. 29. 1 In April 2016, he was promoted to Lieutenant. Id.

In March 2017, Gulley filed a charge of discrimination with the Equal Employment

Opportunity Commission (“EEOC”) alleging racial discrimination and retaliation from June 21,

2014, until February 28, 2017. Charge of Discrimination (“March 2017 Charge”), ECF No. 23-

4. In that charge, Gulley alleged that his supervisors wrongfully accused him of engaging in an

extramarital affair with one of his subordinates. March 2017 Charge at 4. He also alleged that

MPD unjustly suspended him for 15 days for disobeying a direct order after he patrolled with

that subordinate, despite Gulley’s claim that no one ever issued him the order. Id.; see January

2015 DRB Rpt., ECF No. 24-2 (finding that Gulley disobeyed his supervisor’s orders by

changing the subordinate’s vehicle assignment without authorization and patrolling outside his

assigned area). And he said his supervisors revoked his police powers and transferred him to a

new assignment “out of retaliation.” March 2017 Charge at 5; see id. at 4–5. Gulley also said

that “[b]ecause of the discipline” MPD had imposed, he “was disqualified from” a position for

which he had applied as a Sergeant with the Homeland Security Bureau–Tactical Information

Division. Id. at 5. Instead, he claimed, “my spot was given to a black female . . . who did not

even apply.” Id.

1 All page numbers refer to the pagination that the Court’s CM/ECF system generates.

2 Gulley’s March 2017 Charge also included claims of discrimination after MPD promoted

him in April 2016. He challenged a 15-day suspension without pay that his new supervisor

levied after Gulley inappropriately authorized the strip search of a prisoner. Id. at 6. He also

objected to his suspension without pay for 20 days for failing to account for the keys to a police

cruiser and for not going to the scene of a serious event, despite Gulley’s assessment “that the

event was not serious and two other lieutenants were on scene.” Id. And Gulley complained that

an African-American Sergeant made a racially motivated complaint against him, for which he

was demoted from Lieutenant back to Sergeant and suspended without pay for 30 days, while the

Sergeant went unpunished. Id. at 6–7. Finally, Gulley challenged a February 2017 suspension

without pay for 65 days. Id. at 7.

The EEOC responded by form letter on August 10, 2017. Dismissal and Notice of Rights

(“August 2017 Right-to-Sue”), ECF No. 23-5. The EEOC informed Gulley that it was “unable

to conclude that the information obtained establishes violations of the statutes.” Id. It informed

Gulley of his right to sue for the allegations. Id. In capitalized, underlined, boldfaced type, the

letter warned Gulley that for any claim under Title VII, “Your lawsuit must be filed WITHIN

90 DAYS of your receipt of this notice; or your right to sue based on this charge will be lost.”

Id.

In April 2018, Gulley filed a second Charge of Discrimination with the Virginia Division

of Human Rights and the EEOC, again for racial discrimination and retaliation. Charge of

Discrimination (“April 2018 Charge”), ECF No. 23-6. In it, Gulley again raised his claim that he

was punished unjustly after the African-American Sergeant complained about him. Id. at 1; cf.

March 2017 Charge at 6–7. Gulley added that since his March 2017 Charge, he had reported to the

Internal Affairs Division (“IAD”) that the Sergeant had perjured herself at his disciplinary hearing,

but the IAD failed to investigate his complaint. April 2018 Charge at 1. And to bolster his claim of

3 discrimination, Gulley cited an incident in October 2017 in which two Hispanic officers were

arrested for directing racial slurs and profanity at African-American officers yet faced no discipline.

Id. Finally, Gulley claimed that MPD had retaliated against him for filing his IAD complaint against

the African-American Sergeant. Id. 2

Like its response to his first charge of discrimination, the EEOC once again sent Gulley a

form letter response to the April 2018 Charge. Dismissal and Notice of Rights (“August 2018

Right-to-Sue”), ECF No. 23-7. The EEOC sent that letter on August 14, 2018. Id. Once again,

the EEOC was unable to verify the claims. Id. And it included the same deadline for Gulley to

file a civil suit within 90 days. Id. This time Gulley did so. He filed his Complaint here exactly

90 days later. Compl., ECF No. 1.

After Gulley filed his Complaint, the IAD completed a 100-page investigative report into

many allegations of on- and off-duty misconduct against him. April 2019 IAD Rpt., ECF No.

24-10. That investigation sustained nine allegations against Gulley. See id. at 1–5. Among

them was an incident in January 2019 that the IAD concluded was “conduct unbecoming an

officer, including acts detrimental to good discipline, conduct that would adversely affect the

employee’s or the agency’s ability to perform effectively.” Id. at 2. The investigation found that

Gulley threatened to kill his wife and members of MPD in front of his 16-year-old daughter,

2 This last claim appears to refer to MPD’s handling of a disciplinary proceeding in 2017–18. According to Gulley,

On September 15, 2016, Plaintiff was served with Proposed Adverse Action of a fifteen (15)-day suspension, DRB# 604-16, a twenty (20)-day suspension, DRB# 541-16, and a thirty (30) day suspension and demotion, DRB# 676-16. All were served on Plaintiff in writing at the Sixth District. All were appealed through the Chief of Police and denied. Final Agency Action was served in writing for all said Adverse Actions on January 12, 2017.

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