Archie Little v. District of Columbia Water and Sewer Authority, et al.

Summary

The District of Columbia Court of Appeals affirmed summary judgment for C&E Services, Inc. and the District of Columbia Water and Sewer Authority in an age-discrimination action under the District of Columbia Human Rights Act and a tortious-interference claim. The court held that the appellant presented neither sufficient direct nor circumstantial evidence of age discrimination, including evidence of disparate treatment of similarly situated younger employees. The court also affirmed summary judgment on the interference claim because the record lacked evidence that DC Water caused the appellant’s termination from C&E.

Holdings

1. Summary judgment is proper when the pleadings and record show no genuine issue of material fact and the moving party is entitled to judgment as a matter of law; conclusory allegations do not prevent summary judgment.
2. Little did not produce direct evidence sufficient to permit a jury to find that a discriminatory attitude was more likely than not a motivating factor in his alleged termination.
3. Little failed to establish a prima facie case of age discrimination because he did not show that he was treated differently from similarly situated younger employees.
4. Summary judgment for DC Water was proper because Little presented no evidence creating a genuine issue of material fact that DC Water took action interfering with his employment relationship with C&E and caused his termination.

Questions Presented

1. Whether the trial court properly granted summary judgment to C&E and DC Water on Little's age-discrimination claim under the DCHRA.
2. Whether Little presented direct evidence that age was a motivating factor in the alleged termination.
3. Whether Little established a prima facie case of age discrimination through circumstantial evidence, including evidence of disparate treatment compared with similarly situated younger employees.
4. Whether Little presented sufficient evidence that DC Water intentionally interfered with his employment relationship with C&E.

Disposition

affirmed