Simms v. Buttigieg

CourtDistrict Court, District of Columbia
DecidedMarch 14, 2025
DocketCivil Action No. 2022-2115
StatusPublished

This text of Simms v. Buttigieg (Simms v. Buttigieg) 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
Simms v. Buttigieg, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SYDNEY SIMMS,

Plaintiff,

v. Case No. 22-cv-2115-MJS

SEAN DUFFY, Secretary of Transportation,

Defendant.

MEMORANDUM OPINION

Plaintiff Sydney Simms (“Simms”) began working as an employee with the Federal

Aviation Administration (“FAA”)—an agency within the U.S. Department of Transportation—in

February 2020.1 Less than a year later, in January 2021, the FAA terminated her employment. The

FAA cited as its rationale Simms’ “significant performance deficiencies” during her probationary

period. Simms suspects something more sinister. She says she was fired for unlawful

discriminatory reasons, including based on her race (African American), gender (female), age (54

at the time), and disability (an anxiety disorder). To that end, Simms filed claims under Title VII

of the Civil Rights Act of 1964 (“Title VII”), the Age Discrimination in Employment Act of 1967

(“ADEA”), and the Americans with Disabilities Act (“ADA”). Following discovery, the FAA

moved for summary judgment, and the matter is fully briefed. (ECF Nos. 15, 17, 19.) Because the

undisputed material facts demonstrate that no reasonable jury could find that Simms was

terminated because of unlawful discrimination, the Court GRANTS the FAA’s motion.

1 Simms originally sued the previous Transportation Secretary, Pete Buttigieg, but Secretary Sean Duffy was automatically substituted upon his confirmation as Buttigieg’s successor. See Fed. R. Civ. P. 25(d). FACTUAL BACKGROUND

The following facts are either undisputed or construed in favor of Simms as the non-

moving party. Fed. R. Civ. P. 56(a); Holcomb v. Powell, 433 F.3d 889, 895 (D.C. Cir. 2006).2

Simms began her employment with the FAA on February 3, 2020, as a Management and

Program Analyst. (ECF No. 15-2 (“Def.’s Stmt.”) ¶¶ 1–2.)3 As a new employee, Simms was

subject to a one-year probationary period, which meant—according to FAA policy—that she could

“be terminated at any time for performance deficiencies, lack of aptitude for the job, misconduct

and/or lack of cooperation.” (Id. ¶ 4.) Simms reported to the same managers through her

employment, including Ryan Fisher as her first-line supervisor. (Id. ¶ 5.)

By all accounts, Simms performed reasonably well for the first few months. The FAA

reports she had no performance issues throughout the first half of 2020, and she received a passing

review on her mid-year assessment in October 2020. (Id. ¶ 11.) But towards the end of 2020, things

changed. In December 2020 alone, Simms meaningfully missed the mark on three projects.

First, Fisher asked Simms to compile financial information for around three dozen

programs. (Id. ¶ 15.) The following week, Simms told Fisher she completed the project. But on

review, Fisher discovered that nearly three-quarters of the work—26 of the 37 programs requiring

updates—remained incomplete and “contained no information whatsoever.” (Id. ¶ 16.) Fisher

2 Under the Local Rules, “the Court may assume that facts identified by the moving party in its statement of material facts are admitted, unless such a fact is controverted in the statement of genuine issues filed in opposition to the motion.” LCvR 7(h)(1). Here, the FAA filed a separate statement of facts comprising 36 separately numbered paragraphs. (ECF No. 15-2.) Simms filed her own statement (ECF No. 17-1), but it does not respond to the FAA’s proposed undisputed facts at all, much less attempt to “controvert” any of them. So the Court will assume Simms admits the FAA’s proffered facts and will accept them as undisputed. See LCvR 7(h)(1); Fed. R. Civ. P. 56(e)(2) (“If a party … fails to properly address another party’s assertion of fact as required by Rule 56(c), the court may … consider the fact undisputed for purposes of the motion.”); Johnson v. Perez, 823 F.3d 701, 705 (D.C. Cir. 2016) (“[I]f one party presents relevant evidence that another party does not call into question factually, the court must accept the uncontroverted fact.”). 3 Although not material to the resolution of this motion, the Court observes that Simms had previously worked as a contractor for the FAA on a non-employee basis. (See ECF No. 17-2, Pl.’s Ex. 1.)

2 followed up with Simms, asking whether she needed help or had questions. Simms said she did

not and must have just uploaded the wrong file. (Id. ¶¶ 17–18.) But weeks later, by the end of

December, Simms still had not provided Fisher with an updated and corrected report. (Id. ¶ 19.)

Second, Fisher asked Simms to prepare a spreadsheet related to different agency programs

for discussion during an upcoming meeting with the Director and other department executives.

(Id. ¶ 20.) When Fisher first reviewed the spreadsheet Simms prepared, he found several mistakes

and met with Simms to explain what she needed to correct before the meeting. (Id. ¶ 22.) Simms

reported that she made the corrections and assured Fisher the spreadsheet was ready to present.

(Id. ¶ 23.) This was apparently not the case. During the meeting, the participants identified several

significant errors in the data Simms prepared and concluded they could not rely on her data at all.

(Id. ¶ 24.) Afterward, Fisher asked Simms to correct the document once again, but her resulting

work product—even after the fact—still contained mistakes and inaccuracies. (Id. ¶ 25.)

Third, Fisher tasked Simms with providing analysis and corrections on certain budget-

related documents for various FAA program offices. (See id. ¶ 26.) The deadline was set weeks in

advance, and Fisher had several meetings with Simms along the way during which he explained

the type and level of analysis he expected. (Id. ¶ 27–28.) But when Simms ultimately turned in her

deliverables, she failed to include the sort of analysis Fisher discussed with her; she simply ran a

“spell check” on the documents to find typographical errors. (Id. ¶ 29.)

Simms does not dispute any of these facts or even the FAA’s characterization of them. She

simply clarifies that none of these issues was raised in her “satisfactory” performance review in

October 2020. (ECF No. 17-1 (“Pl.’s Stmt.”) ¶¶ 10–11.) Simms also flags that she was never put

on a performance improvement plan prior to termination. (Id. ¶ 15.)

On January 11, 2021, the FAA terminated Simms’ employment. (Def.’s Stmt. ¶ 30.)

3 ANALYSIS

As previewed, Simms claims the FAA unlawfully terminated her employment based on

race and gender discrimination in violation of Title VII (Count I); age discrimination in violation

of the ADEA (Count II); and disability discrimination in violation of the ADA (Count III). Simms

also contends that the FAA “failed to accommodate her disability” under the ADA (Count III).4

The FAA seeks summary judgment across the board.

I. Standard of Review

Summary judgment is appropriate “if the movant shows that there is no genuine dispute as

to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P.

56(a); Anderson v.

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