Source: cases/42usc1981/f3d-924-519-haynes-v-dist-of-columbia-water.case
Case source: https://www.neochart.com/catalog/cases/f3d/volume_924/0519_01/index.html
Although the framework for evaluating Section 1981 claims resembles that for Title VII claims, discrimination under Section 1981 must be intentional
That cannot create a triable issue of fact.
(4) summary judgment on Haynes's Section 1981 claim was appropriate given the record before the district court.
Accordingly, we conclude that the district court did not abuse its discretion in denying Haynes's Rule 56(d) request for discovery.
casedsl 1.2
# author: Flash2 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)
case /f3d/924/0519-01
name Haynes v. Dist. of Columbia Water
cite 924 F.3d 519 (2019)
# IR court field says: Court of Appeals of the District of Columbia
court United States Court of Appeals for the District of Columbia Circuit
date 2019-05-17
url catalog/cases/f3d/volume_924/0519_01/index.html
source ir/caselaw/f3d_924.jsonl sha1=21f9d64f9907fd7b5932e43d04de1800c8ea6a34 chars=44029
opinion maj : majority by Griffith @0..44029 controlling
theory merits : whether the summary-judgment record raised a triable issue of intentional race discrimination
theory rule56d : whether denying pre-discovery Rule 56(d) relief on the Section 1981 claim was an abuse of discretion
? other: D.C. Water is described as an independent agency of the D.C. government, but the opinion never discusses the state-remedial-route (Section 1983 / Monell) for the Section 1981 claim; no block is recorded for it.
law 42usc1981
role applied
posture civil; Section 1981 race discrimination in discharge after reorganization; pre-discovery summary judgment for employer and denial of Rule 56(d) discovery affirmed by CADC
result claimant-lost
element protected-person : satisfied [conceded]
route race
pattern black
fact @3045..3349 [supports] | Haynes, who is over fifty and black, alleges that younger, white electricians employed by D.C. Water received accommodations, including being given more time to obtain their licenses, not being subjected to the heightened license requirement, or being allowed to return to school for additional training.
element own-contract : satisfied [conceded]
route employment-relationship
pattern water-authority-electrician
fact @31..187 [supports] | Haynes had worked at the D.C. Water and Sewer Authority ("D.C. Water") for nearly thirty years when his position was eliminated as part of a reorganization.
element contractual-impairment : satisfied [conceded]
route employment-contract
pattern discharge-for-failure-to-obtain-newly-required-license
fact @5407..5528 [supports] | Haynes failed to complete the journeyman electrician license exam by the extended deadline of May 31, 2015 and was fired.
gloss The discharge itself was undisputed; the court decided the claim on intent/pretext, not on whether a contractual injury occurred.
element racial-intent : not-satisfied [no-evidence]
theory merits
route comparator
pattern alleged-white-comparators-given-more-time-rebutted-by-uniform-licensing-deadlines
cites stage mcdonnell-douglas.pretext
fact @34126..34373 [cuts-against] | D.C. Water then presented evidence that the only electricians subject to new licensure requirements during the reorganization were Electrical Equipment Repairers like Haynes, and that all the Repairers were treated the same (or worse) than Haynes.
fact @5866..6023 [cuts-against] | Along with Haynes, the remaining two black employees did not complete the licensing exam by March 31, 2015 and were given the additional sixty-day extension.
fact @5779..5865 [cuts-against] | Prior to March 31, 2015, one black Repairer and the white Repairer completed the exam.
fact @42332..42498 [cuts-against] | D.C. Water presented evidence that utility workers were not electricians subject to the licensure requirements that Haynes alleges were discriminatorily administered.
fact @42535..42639 [cuts-against absent] | Rather than file a declaration or other materials disputing that evidence, Haynes offered only argument.
rule @28351..28499 | Although the framework for evaluating Section 1981 claims resembles that for Title VII claims, discrimination under Section 1981 must be intentional
held @42640..42683 | That cannot create a triable issue of fact.
held @7922..8033 | (4) summary judgment on Haynes's Section 1981 claim was appropriate given the record before the district court.
gloss The merits ruling is narrow (footnote): the only preserved merits objection was that the district court failed to credit an unsupported assertion about mostly white utility workers. The body of Part II.D is the Rule 56(d) ruling, recorded separately.
element racial-intent : not-reached
theory rule56d
scope procedural
route _procedural
pattern rule-56d-declaration-listing-categories-of-comparator-discovery-without-explaining-necessity
held @39840..39971 | Accordingly, we conclude that the district court did not abuse its discretion in denying Haynes's Rule 56(d) request for discovery.