Thursday, August 27, 2009

Maryland Federal Court Rejects Plaintiff's Retaliation Claims

In Carr v. Prince George's County, Maryland, the United States District Court for the District of Maryland entered summary judgment in favor of the Prince George's County Police Department on the plaintiff's discrimination and retaliation claims. Noteworthy is the Court's decision rejecting the former police officer's claims that she was retaliated against for having complained of discrimination and for filing a charge of discrimination with the EEOC. The Court found that there were not sufficient facts to show that the persons who made the decision to transfer the plaintiff to another unit within the department had knowledge of either her written complaint of discrimination or the EEOC charge at the time they decided to transfer her. The Court noted that knowledge of the protected activity by the decision maker is "absolutely necessary" to establish causation in a retaliation case. A copy of the decision can be read here.

Please visit the Farrell & Gunderson website and contact Eric W. Gunderson if you would like additional information or guidance on discrimination and retaliation claims under Title VII.