Robert Whittaker, III v. Howard County, Maryland

Court of Appeals for the Fourth Circuit·Decided August 20, 2026·No. 23-2019·Unpublished

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-2019

ROBERT D. WHITTAKER, III, Plaintiff - Appellant,

v.

HOWARD COUNTY, MARYLAND; HOWARD COUNTY FIRE AND RESCUE SERVICES,

Defendants - Appellees.

Appeal from the United States District Court for the District of Maryland, at Baltimore. Beth P. Gesner, Magistrate Judge. (1:21-cv-02108-BPG)

Argued: January 27, 2026 Decided: August 20, 2026

Before HARRIS and BENJAMIN, Circuit Judges, and FLOYD, Senior Circuit Judge.

Affirmed by unpublished opinion. Judge Benjamin wrote the opinion, in which Judge Harris and Senior Judge Floyd joined.

ARGUED: Adam L. Shaw, HIJAZI & CARROLL, P.A., Washington, D.C., for Appellant. Erin Brady Purdy, HOWARD COUNTY OFFICE OF LAW, Ellicott City, Maryland, for Appellee. ON BRIEF: Levi S. Zaslow, Abdullah H. Hijazi, HIJAZI, ZASLOW & CARROL, P.A., Bowie, Maryland, for Appellant. Gary W. Kuc, County Solicitor, Jamar B. Herry, HOWARD COUNTY OFFICE OF LAW, Ellicott City, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

DEANDREA GIST BENJAMIN, Circuit Judge:

Robert Whittaker was selected by the Howard County Department of Fire and Rescue Services (the “Department”) to participate in its training academy. At age 46, he was the oldest trainee in his class. Whittaker advanced through the Department’s training academy (the “Academy”) but was terminated just before graduation. That termination was based on Whittaker’s insubordination and poor performance at the Academy. Whittaker sued Howard County, Maryland, alleging that he was actually terminated due to his age in violation of the Age Discrimination in Employment Act.

The magistrate judge granted summary judgment for Howard County finding that Whittaker did not make a prima facie case of age discrimination and that he failed to show that the Department’s nondiscriminatory reasons were mere pretext.

We affirm, holding that Whittaker fails to make a prima facie case because there is no genuine dispute as to whether he met the Department’s legitimate expectations.

I. Whittaker’s Training Academy Experience At age 46, Robert Whittaker applied for a trainee position with the Department. He was selected from 1,800 applicants after passing all disqualifiers (i.e., criminal background check, drug testing, driving history, etc.), a written test, a physical agility test, a panel interview, a background check, a psychological examination, and a physical examination. In January 2018, he started the Academy as the oldest trainee. As a trainee, Whittaker was a probationary employee.

The Academy lasts for approximately six months and consists of different units used to prepare trainees for firefighting duties and measure their abilities to perform those duties. The training program covered academic coursework in Emergency Medical Technician (EMT), Emergency Vehicle Operator, HAZMAT Tech, HAZMAT Operations, Swiftwater Awareness, Confined Space, Trench Rescue, and Firefighter I and Firefighter II units. Trainees were assessed on each unit and received a certificate to signify their successful completion of each unit. Trainees also engaged in practical exercises like ladder and maze exercises. Academy staff evaluated each trainee throughout the Academy and discussed training progress with the trainees and Department leadership. During the Academy,1 Whittaker says that Captain Douglas Welsh, the head instructor for Whittaker’s training class, told him “you don’t do half bad for an old guy.” J.A. 0007.2 If a performance issue arose during training, Academy staff issued Student Counseling/Status Report Forms (“Counseling Reports”). Each report was discussed with and then signed by the trainee.

Whittaker successfully completed all the academic instruction necessary to become a firefighter. And his fellow trainees did not observe any deficiency with his performance.

1

As noted by the magistrate judge: “neither party provides a date for this incident.

[the Department] suggests that Captain Welsh referred to plaintiff as ‘an old guy’ shortly after [Whittaker] began Firefighter 1 training. [Whittaker] merely asserts that the statement was made during [his] time at the Academy.” Whittaker v. Howard Cnty., Maryland, No. CV BPG-21-2108, 2023 WL 5336993, at *3 n.1 (D. Md. Aug. 17, 2023).

2

Citations to “J.A.” refer to the joint appendix filed by the parties. The J.A. contains the record on appeal from the lower court. Page numbers for citations to the J.A. utilize the “J.A. #” numbering at the bottom of the page on each document.

However, as included in the timeline of events below, Academy staff documented concerns regarding Whittaker’s performance during his training:

Date Event(s)

January 28, 2018 Whittaker was hired as a trainee for the Academy.

April 16, 2018 Whittaker received a Counseling Report regarding an incident from April 13 where he did not complete a ladder climbing scenario and requested to evacuate into the interior of the structure due to his hesitancy around heights. He later completed the objective on April 16.

April 17, 2018 An Academy captain sent an internal memo to Welsh discussing Whittaker’s disorientation during a maze exercise and his reaction to stress.

April 18, 2018 Whittaker received a Counseling Report related to exercises from April 17 noting that he “became disoriented in the maze,” “[had] issues with ladder operations” and “becam[e]

insubordinate” “when placed under minimal stressful situations.” J.A. 1301. Whittaker rejected the characterization of his conduct as insubordinate.

Whittaker successfully completed a ladder climbing scenario. Though, an Academy captain and Welsh sent internal memos discussing his struggle with ladder and maze exercises and stress.

April 24, 2018 Assistant Chief Jose Sanchez sent an internal memo to Deputy Chief Daniel Merson discussing Whittaker’s training: “[S]everal deficiencies have been documented for which [Whittaker] has been counseled involving ladders, navigating mazes, and talking back to instructors when he becomes stressed or flustered delaying the task completion when ordered to do so.” J.A. 1186.

May 3, 2018 Whittaker received a Certificate of Completion for Firefighter I on his second attempt. He also received a Counseling Report noting a “pattern” where Whittaker “becomes frustrated” and was “quick to quit . . . and becomes insubordinate.” J.A. 1187.

May 17, 2018 A captain sent an internal memo to Sanchez and Battalion Chief Shawn Utz calling Whittaker’s performance “beneath satisfactory” and noting that “Trainee Whittaker was successful with the minimal requirements set by University

of Maryland Fire & Rescue Institute to pass Firefighter 1 but still demonstrates poor performance when expected to conduct those same skill sets under stress in a team environment.” J.A. 1193.

Department captains exchanged emails about Whittaker’s lack of fireground speed and noting that the issue was discussed “at length” with Whittaker, J.A. 1302, and about two incidents where Whittaker did not properly attach his breathing apparatus.

May 18, 2018 Sanchez recommended dismissing Whittaker in a formal memo to Deputy Chief William Anuszewski noting that “[a]lthough performing at a minimal level academically, Trainee Whittaker’s overall proficiency and behavior do not embody the principle to which this Department holds its prospective academy class graduates.” J.A. 1299–1300.

Another captain sent an internal memo to Sanchez and Utz noting that Whittaker’s performance had caused concern to many instructors. The memo noted that while Whittaker had “shown acceptable progress in the academic portion of the course,” Whittaker became “frustrated and insubordinate”

when it was time to perform the tasks in real life. J.A. 1194.

He also noted that Academy staff delayed their final recommendation to dismiss Whittaker to determine whether Whittaker could implement the skills he learned but that he continued to struggle. Id.

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