Peggy Wilson v. Alejandro Mayorkas

Summary

Peggy Wilson sued the Department of Homeland Security for race, sex, and age discrimination after being denied a promotion. The D.C. Circuit affirmed summary judgment for the employer, holding that Wilson forfeited her challenge to the employer's legitimate nondiscriminatory reason by not raising it below, and that she failed to show pretext for race discrimination through hiring protocol deviations, qualifications comparisons, or alleged patterns of discrimination. The court also found insufficient evidence to support her sex and age discrimination claims.

Holdings

1. Wilson offered insufficient evidence in support of her sex and age discrimination claims, so summary judgment was proper.
2. Wilson forfeited the argument by not raising it before the district court.
3. Wilson failed to show that a reasonable factfinder could find pretext.

Questions Presented

1. Whether the district court properly granted summary judgment on Wilson's sex and age discrimination claims.
2. Whether the district court properly granted summary judgment on Wilson's race discrimination claim, including whether the government met its burden under McDonnell Douglas and whether Wilson showed pretext.

Disposition

affirmed