Moreno-Livni v. Afl-Cio Housing Investment Trust

CourtDistrict Court, District of Columbia
DecidedSeptember 11, 2024
DocketCivil Action No. 2024-1392
StatusPublished

This text of Moreno-Livni v. Afl-Cio Housing Investment Trust (Moreno-Livni v. Afl-Cio Housing Investment Trust) 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
Moreno-Livni v. Afl-Cio Housing Investment Trust, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ROSA E. MORENO-LIVINI,

Plaintiff, v. Civil Action No. 24-1392 (JEB)

THE AFL-CIO HOUSING INVESTMENT TRUST, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Rosa Moreno-Livini was fired less than a year and a half after starting a full-time

position as a Managing Director for Defendant AFL-CIO Housing Investment Trust. In her

telling, much of what occurred during that period involved worsening mistreatment at the hands

of her supervisors, culminating in her abrupt termination. Claiming that she was discriminated

against because of her race, gender, and age, she has now sued HIT and three of those

supervisors under various federal and local antidiscrimination statutes. In response, Defendants

have moved to dismiss the case for failure to state a claim, arguing that Plaintiff has not shown

that she was treated worse than similarly situated employees nor otherwise pled sufficient factual

allegations to support an inference of discrimination. Despite the modest bar set for Moreno-

Livini at this stage of the proceedings, she fails to clear it, and so the Court will grant the Motion.

I. Background

The Court draws on the facts as pled in the Complaint, taking them to be true. See

Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1113–14 (D.C. Cir. 2000). Defendant HIT is

1 an investment company registered with the Securities and Exchange Commission that focuses on

investing union workers’ pensions in fixed-income securities. See ECF 1 (Compl.), ¶ 11.

Among its employees are Defendants Chang Suh, its Chief Executive Officer; Lesyllee White,

its Chief Marketing Officer; and Erika Khatchadourian, its Chief Financial Officer and Human

Resources representative. Id., ¶¶ 15–17. In or around May 2020, Defendants hired Plaintiff as a

consultant to develop strategies for institutional-investor outreach and to source a public-

relations firm for the company. Id., ¶ 19. Apparently satisfied with her work, HIT then offered

her a full-time position as a Managing Director focused on institutional business development

and capital raising across defined-contribution channels, primarily public plans. Id., ¶ 23.

Although Moreno-Livini was apparently a standout performer in her first year at the

company, id., ¶ 27, she nonetheless alleges that she was mistreated by her superiors because she

is a “55-year-old Latina woman.” Id., ¶ 10. In comparison with four of her “white, male

colleagues,” id., ¶¶ 25, 28, Plaintiff alleges that she alone was forced to work out of HIT’s

headquarters in the District of Columbia, denied remote-work or hybrid-work options, assigned

lower-level work not suitable for her position, prevented from traveling to conferences for work,

isolated and alienated from her colleagues, and subjected to a hostile work environment. Id.,

¶¶ 24–41. To cap it all off, she was eventually fired over Zoom while recuperating from a

COVID-19 infection. Id., ¶ 43.

Suspecting that race-, sex-, and age-based animus motivated this alleged mistreatment,

Moreno-Livini filed this action, which contains four counts. The first alleges that all four

Defendants violated 42 U.S.C.§ 1981, which prohibits race-based discrimination in employment.

See Compl., ¶¶ 56–60. Count II alleges that HIT violated Title VII of the Civil Rights Act,

which prohibits employers from discriminating on the basis of race, color, sex, or national origin,

2 id., ¶¶ 61–66, and Counts III and IV invoke the Age Discrimination and Employment Act, id.,

¶¶ 67–69, and the District of Columbia Human Rights Act, respectively. Id., ¶¶ 70–73. After

Defendants moved to dismiss, Plaintiff dropped both Count III and the Count I claim against

Khatchadourian. See ECF No. 9 (Opp.) at 16–17.

II. Legal Standard

In evaluating Defendants’ Motion to Dismiss, the Court must “treat the complaint’s

factual allegations as true . . . and must grant plaintiff the benefit of all inferences that can be

derived from the facts alleged.” Sparrow, 216 F.3d at 1113 (cleaned up). For a plaintiff to

survive a 12(b)(6) motion, the facts alleged in the complaint “must be enough to raise a right to

relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). That

means a plaintiff must put forth “factual content that allows the court to draw the reasonable

inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009). The court need not accept as true “a legal conclusion couched as a factual

allegation,” nor an inference unsupported by the facts set forth in the complaint. Trudeau v. Fed.

Trade Comm’n, 456 F.3d 178, 193 (D.C. Cir. 2006) (quoting Papasan v. Allain, 478 U.S. 265,

286 (1986)).

III. Analysis

With Count III withdrawn, the Court need address only Counts I, II, and IV. Ultimately,

Moreno-Livini’s failure to plausibly allege that her white, male coworkers were similarly

situated to her dooms both her § 1981 and Title VII claims. After thus dismissing those two

counts, the Court will decline to exercise supplemental jurisdiction over her DCHRA claim.

3 A. Count I

Section 1981 protects the equal right of “[a]ll persons within the jurisdiction of the

United States” to “make and enforce contracts” — including “the enjoyment of all benefits,

privileges, terms, and conditions of the contractual relationship” — without respect to race. See

42 U.S.C. § 1981(a)–(b). “[T]o state a claim for racial discrimination under Section 1981, a

plaintiff must allege that (1) the plaintiff is a member of a racial minority; (2) the defendant

intended to discriminate against the plaintiff on the basis of race; and (3) the discrimination

concerned an activity enumerated in § 1981.” Mazloum v. Dist. of Columbia Metro. Police

Dep’t, 522 F. Supp. 2d 24, 37 (D.D.C. 2007) (internal quotation marks omitted). The statute

encompasses employment contracts such as the one here. See Ayissi-Etoh v. Fannie Mae, 712

F.3d 572, 576 (D.C. Cir. 2013).

“To plead intentional discrimination, a plaintiff cannot merely invoke his race, but must

allege some facts to show that race was the reason for the defendant’s action.” Wilson v. DNC

Servs. Corp., 315 F. Supp. 3d 392, 400 (D.D.C. 2018). That is not to say, however, that a

plaintiff must at this stage plead a prima facie case of discrimination under the burden-shifting

framework articulated in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). See

Swierkiewicz v. Sorema N.A., 534 U.S. 506, 508 (2002). Rather, the complaint must simply

“contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on

its face.’” Iqbal, 556 U.S.

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