Roberts-Gregory v. American Association for the Advancement of Science

Summary

The United States District Court for the District of Columbia addresses Federal Defendants’ motion to dismiss claims brought by Frances Roberts-Gregory concerning an American Association for the Advancement of Science fellowship stipend and the revocation of her fellowship offer. The court concludes that it has jurisdiction over the Equal Pay Act retaliation claim, that the complaint fails to state a disparate-treatment claim under Title VII, and that it adequately states disparate-impact and Title VII retaliation claims. The motion to dismiss is therefore granted in part and denied in part.

Holdings

1. The court had jurisdiction over Roberts-Gregory's Equal Pay Act retaliation claim because the retaliation claim sounded in tort and therefore did not fall within the Tucker Act's grant of jurisdiction over non-tort claims against the United States.
2. The complaint failed to state a plausible claim that the Federal Defendants intentionally discriminated against Roberts-Gregory because of her race or sex.
3. The complaint plausibly stated a Title VII disparate-impact claim based on the stipend policy's prior-salary exception and engineering exception.
4. The complaint plausibly stated a Title VII retaliation claim against the Federal Defendants.

Questions Presented

1. Whether the district court had subject-matter jurisdiction over Roberts-Gregory's Equal Pay Act retaliation claim against the United States.
2. Whether the complaint plausibly alleged disparate-treatment race or sex discrimination under Title VII.
3. Whether the complaint plausibly alleged a Title VII disparate-impact claim based on the stipend policy's prior-salary and engineering exceptions.
4. Whether the complaint plausibly alleged Title VII retaliation against the Federal Defendants based on revocation of the fellowship offer.

Disposition

other