Keith v. U.S. Government Accountability Office

CourtDistrict Court, District of Columbia
DecidedAugust 29, 2022
DocketCivil Action No. 2021-2010
StatusPublished

This text of Keith v. U.S. Government Accountability Office (Keith v. U.S. Government Accountability Office) 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
Keith v. U.S. Government Accountability Office, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CAMILLE KEITH, : : Plaintiff, : Civil Action No.: 21-2010 (RC) : v. : Re Document No.: 4 : U.S. GOVERNMENT ACCOUNTABILITY : OFFICE, : : Defendant. :

MEMORANDUM OPINION

GRANTING DEFENDANT’S MOTION TO DISMISS

I. BACKGROUND

This case comes before the Court on Defendant U.S. Government Accountability

Office’s (“GAO”) motion to dismiss for failure to state a claim, so the Court accepts the factual

allegations in Plaintiff Camille Keith’s Complaint as true at this stage and summarizes them

here. See, e.g., Robb v. Vilsack, No. CV 20-0929, 2021 WL 3036796, at *1 n.2 (D.D.C. July 19,

2021). Keith, an “African American female” in her forties who has a hearing-impairment

disability, was a forensic audits analyst at GAO. Compl. ¶¶ 12, 16, 18, ECF No. 1. She has a

17-year record of “exemplary work performance” at GAO. Id. ¶ 22. In August 2018, Keith was

assigned to a team tasked with examining for fraud and related issues at the Federal Emergency

Management Agency (“FEMA”). Id. ¶¶ 19, 23. “Ms. Fagan,” whose first name Keith does not

recall, served as Keith’s supervisor or “Designated Performance Manager.” See id. ¶ 20.

At some point, apparently in May 2019, Keith received her “2018 performance appraisal

rating.” Id. ¶ 23. Unhappy with the review, she disputed it. Id. Keith does not specify on what

grounds she disputed her 2018 performance appraisal rating. See id. But GAO was displeased that Keith had disputed the review, so it retaliated against her by failing to give her “constructive

feedback that would have allowed her to improve her work performance for the 2019 appraisal

period.” Id. The result was a negative 2019 performance appraisal that rated Keith’s work

“unacceptable” in several categories. Id.

Also while on the FEMA engagement, Keith received “unreasonable time constraints to

complete her projects”; for example, her supervisors required her to complete a “Record of

Interview” and a related “review of a 65-page monitoring document,” within one day after the

interview. Id. ¶ 24. Other examples included being assigned to lead a meeting with only “a

couple of hours to prepare,” and being told “at the end of the workday” that she had to

“completely revise a document by the next morning.” Id.

Keith further complains that she “was barred from travelling with the team on site visits”

in February 2019. Id. ¶ 25. Thus, when the rest of the team prepared to travel to Texas, Fagan

told Keith she would not be joining. Id. Keith later asked whether she would join the team on a

trip to California, and “Fagan replied no due to ‘team structure.’” Id.

To make matters worse, in June 2019, the human resources office told Keith that she

could no longer work from home under a “telework arrangement” because of her “unacceptable

work performance.” Id. ¶ 26. Keith says that this was the first she had heard of this criticism of

her work; she therefore did not have the opportunity to receive “constructive feedback” before

losing the privilege of working remotely. Id.

All of this was punctuated by a series of unpleasant interactions involving Keith’s

hearing disability that “made her feel upset, uncomfortable, and belittled.” Id. ¶ 27. Once, Keith

announced to her team that she would be getting hearing aids. Id. Fagan responded, “Good.”

Id. Keith asked what Fagan meant, and Fagan clarified, “you’re getting help.” Id. Keith

2 “responded [that] she did not think there was anything good about being 44 years old and getting

hearing aids.” Id. Separately, during meetings, another “co-worker,” Director Rebecca Shea,

“kept asking ‘Can you hear, can you hear’”? Id. ¶¶ 20, 27. Still another “co-worker,” “Analyst-

in-Charge” Erin Villas, “compared [Keith] getting hearing aids to her sister getting glasses.” Id.

¶ 27. Keith made it clear that she considered these comments offensive and that they made her

uncomfortable. Id. at ¶ 27. GAO “managers” also provided Keith with “conflicting instructions

about whether to speak up when she could not hear.” Id. At first, they told her not to interrupt

meetings when she could not hear because she would receive notes after the meeting. Id. But

then, they turned around and told her “it was unacceptable not to speak up if [she] could not

hear.” Id.

In the instant lawsuit, Keith alleges that the lack of constructive feedback, 2019 negative

performance appraisal, ban from site-visit travel, termination of her telework option, “negative

comments about her disability,” and “conflicting directions regarding her participation in work

activities,” were retaliation for activity protected by Title VII of the Civil Rights Act of 1964,

namely Keith’s “disput[e] [of] her 2018 performance appraisal rating.” Id. ¶¶ 70–71. Keith

further alleges that each of these same events constituted discrimination on the basis of her race

and sex in violation of Title VII, as well as discrimination on the basis of her age in violation of

the Age Discrimination in Employment Act of 1967 (“ADEA”) and discrimination on the basis

of her hearing disability in violation of the Americans with Disabilities Act of 1990 (“ADA”).

Id. ¶¶ 30, 51, 91 96. In response, GAO moves under Federal Rule of Civil Procedure 12(b)(6) to

dismiss the Complaint for failure to state a claim upon which relief can be granted. Def.’s Mot.

Dismiss, ECF No. 4.

3 II. LEGAL STANDARD

The Federal Rules of Civil Procedure require that a complaint contain “a short and plain

statement of the claim” sufficient to give the defendant fair notice of the claim and the grounds

upon which it rests. Fed. R. Civ. P. 8(a)(2); accord Erickson v. Pardus, 551 U.S. 89, 93 (2007)

(per curiam). A motion to dismiss under Rule 12(b)(6) “tests the legal sufficiency of a

complaint” under that standard; it asks whether the plaintiff has properly stated a claim.

Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002). “To survive a motion to dismiss, a

complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is

plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 570 (2007)). This means that a plaintiff’s factual allegations “must be

enough to raise a right to relief above the speculative level, . . . on the assumption that all the

allegations in the complaint are true (even if doubtful in fact).” Twombly, 550 U.S. at 555–56

(citations omitted). “Threadbare recitals of the elements of a cause of action, supported by mere

conclusory statements,” are therefore insufficient to withstand a motion to dismiss. Iqbal, 556

U.S. at 678. A court need not accept a plaintiff’s legal conclusions as true, see id., nor must a

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