Kathleen Stanley McCaffery v. Fairfax County

Summary

The United States District Court for the Eastern District of Virginia considers Fairfax County’s motion for summary judgment in Kathleen Stanley McCaffery’s employment-related retaliation and discrimination action. The court grants the motion in part and denies it in part, addressing alleged retaliation following McCaffery’s participation in an organizational climate review, her resignation from a women’s program officer role, internal investigations, press conferences, and proposed reassignment.

Holdings

1. Summary judgment was denied because the record, viewed in McCaffery's favor, presented a genuine dispute as to whether the alleged retaliatory conduct was unwelcome, attributable to the County, and sufficiently severe or pervasive that it could dissuade a reasonable worker from making or supporting a discrimination charge.
2. Summary judgment was granted to Fairfax County on the sex-discrimination and retaliation claims arising from McCaffery's nonselection for Fire Chief because she failed to present sufficient evidence that the County's legitimate explanation—that the selected candidate was better qualified based on performance and experience—was pretextual.

Questions Presented

1. Whether McCaffery presented sufficient evidence to create a genuine dispute that she experienced a retaliatory hostile work environment under Title VII.
2. Whether Fairfax County was entitled to summary judgment on McCaffery's Title VII sex-discrimination claim based on her nonselection for Fire Chief.
3. Whether Fairfax County was entitled to summary judgment on McCaffery's Title VII retaliation claim based on her nonselection for Fire Chief.

Disposition

other