Shanks v. International Union of Bricklayers and Allied Craftworkers

CourtDistrict Court, District of Columbia
DecidedJuly 7, 2026
DocketCivil Action No. 2023-0311
StatusPublished

This text of Shanks v. International Union of Bricklayers and Allied Craftworkers (Shanks v. International Union of Bricklayers and Allied Craftworkers) 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.

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Shanks v. International Union of Bricklayers and Allied Craftworkers, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SAMUEL SHANKS,

Plaintiff, v. Civil Action No. 23-0311 (CKK) INTERNATIONAL UNION OF BRICKLAYERS AND ALLIED CRAFTWORKERS,

Defendant.

MEMORANDUM OPINION & ORDER (July 7, 2026)

In this action, pro se Plaintiff Samuel Shanks alleges that his former employer

discriminated against him and retaliated against him for engaging in protected activity, culminating

in his termination in October 2021. Mr. Shanks has filed a proposed amended complaint, which

the Court construes as a motion for leave to amend his operative complaint. The Defendants

oppose this motion,1 and Mr. Shanks has filed a reply. Upon consideration of the parties’

submissions,2 the relevant legal authority, and the entire record, the Court shall GRANT IN PART

and DENY IN PART Mr. Shanks’s motion. The Court shall GRANT leave to amend the

operative complaint to (1) add Mr. Shanks’s newly proposed factual allegations in support of his

claims of race discrimination and (2) add a new race discrimination claim under 42 U.S.C. § 1981.

The Court shall otherwise DENY leave to amend.

1 The Court uses the term “Defendants” to refer collectively to current Defendant International Union of Bricklayers and Allied Craftworkers (“BAC”) and two individual employees of BAC who Mr. Shanks proposes to join as parties. 2 The Court’s consideration has focused on the following documents, including the attachments and exhibits thereto: Mr. Shanks’s Proposed Amended Complaint, Dkt. No. 43; the Defendants’ Opposition to the Plaintiff’s Motion for Leave to Amend Complaint, Dkt. No. 44; and Mr. Shanks’s Reply in Support of the Motion for Leave to Amend Complaint, Dkt. No. 45. In an exercise of its discretion, the Court concludes that oral argument is not necessary to the resolution of the issues pending before the Court. See LCvR 7(f).

1 I. BACKGROUND

Plaintiff Samuel Shanks was employed in the accounting department of the International

Union of Bricklayers and Allied Craftworkers (“BAC”) for more than 20 years. Proposed Am.

Compl., Dkt. No. 43, ¶ 1.

In October 2021, BAC terminated Mr. Shanks’s employment, citing its policy requiring

employees to become vaccinated against COVID-19, which Mr. Shanks had not done by the

deadline that BAC set. Proposed Am. Compl. ¶ 21. Mr. Shanks alleges that this policy was

“implemented differently than past employment policies” in several respects. Id. ¶ 17. Notably,

he alleges that Black employees received less advance notice of the new policy than White

employees did. See id. ¶ 23. He further alleges that BAC’s Black employees were denied access

to information about the COVID-19 vaccine, including resources that BAC received as part of a

partnership with the White House and the U.S. Department of Health and Human Services. Id.

¶ 10. Mr. Shanks alleges that BAC’s rollout of its COVID-19 vaccine requirement was part of a

pattern of discrimination against its Black employees. See id. ¶¶ 10–11, 16, 18.

Mr. Shanks also alleges that the Defendants took several actions in connection with his

termination that caused him emotional distress and related symptoms and conditions, including

post-traumatic stress disorder, panic attacks, and anxiety. Proposed Am. Compl. ¶¶ 49–50. He

alleges that the Defendants terminated him “via UPS” and shipped his personal belongings to him

“without [a] tracking number,” resulting in his belongings “being left out in the rain.” Id. ¶ 50.

He also alleges that BAC subjected him to “surveillance by management” and “proxy targeting of

family [and] friends.” Id.

Mr. Shanks filed an administrative charge of discrimination against BAC with the Equal

Employment Opportunity Commission, which was cross-filed with the D.C. Office of Human

Rights on April 1, 2022. Proposed Am. Compl. ¶ 19; see also Charge of Discrimination, Dkt. No. 2 20-1 at 22. In this administrative complaint, Mr. Shanks, who is Black and describes himself as

having “pre-existing medical conditions,” alleged that he had “been the victim of retaliation” and

had “been discriminated against due to [his] race” and “because of [his] disability.” See id ¶¶ 19,

22–23, 40; Charge of Discrimination, Dkt. No. 20-1 at 22.

In his description of the particulars of this administrative complaint, Mr. Shanks named

three BAC employees including, as relevant here, BAC President Timothy Driscoll. See Dkt. No.

20-1 at 22. Mr. Shanks alleged that in October 2021, he sent an email to Mr. Driscoll in which he

“went into detail [about] racial discrimination” and “requested a reasonable accommodation”

regarding BAC’s COVID-19 vaccine mandate. Id. Mr. Shanks further alleged that “[s]hortly

thereafter, [he] received a suspension letter and following that . . . a termination letter.” Id. Mr.

Shanks also alleged that he had complained to Mr. Driscoll and at least one other executive several

months earlier, in March 2021, that he “felt [he] was being treated poorly due to [his] race.” Id.

Mr. Shanks received a right-to-sue letter on September 26, 2022. See Proposed Am. Compl. ¶ 20.

Mr. Shanks later filed this action in D.C. Superior Court on December 23, 2022, asserting

race, sex, and disability discrimination, hostile work environment, and retaliation claims against

BAC under Title VII of the Civil Rights Act of 1964 (“Title VII”), the Americans with Disabilities

Act of 1990 (“ADA”), and the District of Columbia Human Rights Act (“DCHRA”). See Dkt.

No. 1-1 at 4–5. BAC removed the action to this Court and moved to dismiss the action for failure

to state a claim. See Notice of Removal, Dkt. No. 1; Mot. to Dismiss, Dkt. No. 8. The Court

granted that motion. Order, Dkt. No. 21. Mr. Shanks appealed this dismissal to the U.S. Court of

Appeals for the D.C. Circuit, which summarily affirmed the dismissal of Mr. Shanks’s retaliation

and disability discrimination claims, and later affirmed the dismissal of his sexual orientation and

hostile work environment claims. Shanks v. Int’l Union of Bricklayers & Allied Craftworkers

3 (“Shanks I”), No. 23-7141, 2024 WL 2790385, at *1 (D.C. Cir. May 29, 2024); Shanks v. Int’l

Union of Bricklayers & Allied Craftworkers (“Shanks II”), 134 F.4th 585, 597–98 (D.C. Cir. 2025).

However, the D.C. Circuit reversed the dismissal of Mr. Shanks’s claims of race discrimination

and remanded those claims to this Court for further proceedings. Shanks II, 134 F.4th at 598.

Upon remand to this Court, BAC filed an Answer on June 27, 2025, and the Court ordered

that “the deadline to join additional parties or amend pleadings” would be August 18, 2025.

Answer, Dkt. No. 34; Order, Dkt. No. 40. At Mr. Shanks’s request, the Court extended that

deadline to August 25, 2025. See Minute Order (Aug. 19, 2025).

On the day of the deadline to amend pleadings or join additional parties, Mr. Shanks filed

a proposed Amended Complaint. Dkt. No. 43. In this filing, Mr. Shanks proposes to add new

factual allegations in support of his Title VII and DCHRA claims; to add a race discrimination

claim under 42 U.S.C. § 1981; to join BAC President Timothy Driscoll and BAC Executive

Director Candice Dubberly as Defendants; to reassert claims of sex and disability discrimination,

retaliation, and hostile work environment; to add new tort claims for “Concealment” or

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