OMWENGA v. UNITED NATIONS FOUNDATION

Filing 52

MEMORANDUM OPINION regarding Defendant's Motion for Summary Judgment 40 . Signed by Judge Tanya S. Chutkan on 9/30/2019. (lctsc3)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Corrine Omwenga,
Plaintiff,
v.
United Nations Foundation
Defendant.

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Civil Action No. 15-cv-786 (TSC)

MEMORANDUM OPINION
In this employment discrimination and retaliation action, Plaintiff Corrine Omwenga
alleges eight claims against The United Nations Foundation (UNF), her past employer: (1)
violation of the anti-retaliation provision of the Federal False Claims Act (FCA); (2) common
law wrongful termination in violation of District of Columbia public policy; (3) discrimination
under the District of Columbia Human Rights Act (DCHRA); (4) retaliation under DCHRA; (5)
discrimination based on National Origin/Race under Title VII of the Civil Rights Act of 1964
(Title VII); (6) discrimination based on sex under Title VII; (7) retaliation under Title VII; and
(8) whistleblower retaliation under the National Defense Authorization Act (NDAA).
UNF has moved for summary judgment pursuant to Federal Rule of Civil Procedure 56.
For the reasons set forth below, the motion will be GRANTED in part and DENIED in part.

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I. BACKGROUND 1
A. Omwenga’s Hiring
Omwenga is a black woman from Kenya who was employed by UNF as a compliance
officer from August 4, 2014 until she was terminated on February 18, 2015. See Plaintiff’s
Response to Defendant’s Statement of Facts (“Pl. Resp. to Def.’s SOF”), ECF No. 46-1 ¶¶ 2, 20,
92.
Before Omwenga’s employment at UNF, she applied for a newly created position,
Director of Business Services and Budgets, but she was never interviewed. See id. ¶ 11. Instead,
UNF hired Andrew McDermott, a white male. See id. ¶ 17. UNF contends that McDermott was
interviewed based on the experience on his resume and hired because of his “superior
performance” during his interview. Id. ¶¶ 15, 17. UNF further argues that Omwenga was not
interviewed for the position because David Burton, Executive Director of Budgets for the UNF,
felt she lacked the required qualifications, such as a “heavy budgets and enterprise-level kind of
view,” which he sought in a prospective director. Id. ¶¶ 11, 12. Omwenga disputes this
contention by (1) pointing to individuals who were hired without meeting the minimum
requirements for positions, (2) noting that the Executive Director had access to Omwenga’s
resume, which divulged her national origin, and (3) claiming that all other candidates who were
interviewed and rejected for the director position had more experience than McDermott, but were
women or minorities. See id. ¶¶ 11, 12, 16.
Although Omwenga was not interviewed for the director-level position, she was offered
an interview for the compliance officer position, for which she was ultimately hired, at a salary
higher than initially advertised. Id. ¶¶ 18–21.

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The facts are undisputed by the parties unless otherwise noted.
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B. Omwenga’s Job Responsibilities
As a compliance officer, Omwenga’s job was to “ensure that projects receiving [United
States Government (USG)] funding were fully compliant with the rules and regulations
governing the use of USG funds.” Id. ¶ 24. Compliance officers also performed internal audits
of the government-funded projects, monitored project reporting requirements, provided technical
assistance when monitoring the government grants, and raised compliance concerns about the
government grants. See id. ¶¶ 25–29.
However, Omwenga disputes that all projects receiving USG funding were under her
purview. Id. ¶ 24. In particular, she notes that she was not responsible for compliance of the
Mobile Hub project. Id. On that project, her role was to assist Koki Hurley, the Grant Manager,
with compliance. See id. ¶¶ 44–46; Plaintiff’s Response to Defendant’s Motion for Summary
Judgment (“Pl. Resp. to Mot. Summ. J.”), ECF No. 46, Ex. 20, Axelrod Dep. at 169:3–169:11;
Defendant’s Motion for Summary Judgment (“Def.’s Mot. Summ. J.”), ECF No. 40, Ex. 14,
Axelrod Dep. at 26–27.
C. Complaints About Omwenga’s Work Performance
Starting in late September 2014, some employees began complaining about a lack of
clarity in Omwenga’s e-mails and advice. Pl. Resp. to Def.’s SOF ¶¶ 47–48, Def.’s Mot. Summ.
J., Ex. 20, UNF 809. They claimed that on several occasions, Omwenga would reference a
statute or contractual clause without making the information accessible in laymen’s terms. See
id. ¶¶ 46–48. These complaints were brought mostly to Andrew Axelrod, the Executive Director
of the Mobile Hub Project. See id. ¶¶ 24, 46–49; Def.’s Mot. Summ. J., Ex. 14, Axelrod Dep. at
149–150, Ex. 20, UNFs 824, 842, 846, 867, 897. Axelrod discussed Omwenga’s performance
and professionalism with Burton multiple times. See Pl. Resp. to Def.’s SOF ¶ 49; Def.’s Mot.

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Summ. J., Ex. 14, Axelrod Dep. at 149–150, 161–164. Plaintiff asserts that she was never
informed of any complaints against her. See Pl. Resp. to Def.’s SOF ¶¶ 52, 54–55.
On November 20, 2014, Omwenga had her 90-day review with Burton, during which he
told her that she had successfully completed the introductory period. Id. ¶¶ 50–51. He also
complimented her, stating that she “had done a good job coming into a new position at the
Foundation and making it her own.” Id. ¶ 51; Pl. Resp. to Mot. Summ. J., Ex. 3, Burton Dep. at
145:6–145:19. Burton contends that he was also trying to convey to Omwenga that she needed
to improve her communication skills. Pl. Resp. to Def.’s SOF ¶ 52. Omwenga disputes that
Burton discussed her communication skills, and there is no mention of the subject in the written
summary of the review. Id.; Pl. Resp. to Mot. Summ. J., Ex. 3, Burton Dep. at 147:5–148:3.
Other individuals started to complain about Omwenga in December 2014 and January
2015. See Pl. Resp. to Def.’s SOF ¶ 54; Def.’s Mot. Summ. J., Ex. 20, UNF 965, 985. Walter
Cortes, UNF’s Chief Financial Officer, stated that in December 2014 he started to believe that
Omwenga was not performing her job well. See Def.’s Mot. Summ. J., Ex. 13, Cortez Dep. at
29. He noted that Omwenga interrupted speakers and raised her voice at meetings, traits that
other coworkers had also mentioned. See id. at 29–31. Cortes also claimed that this was the
only time in his ten years at UNF that he could recall an employee complaining about another
employee’s conduct. See id. at 96–98. Around the end of 2014, the head of Human Resources,
Maxine Somerville, was notified about Omwenga’s performance and communication problems.
See Pl. Resp. to Def.’s SOF ¶¶ 60–61. Omwenga was not informed about these problems. See
id.

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Omwenga alleges that she engaged in protected activity when she investigated UNF’s
alleged fraudulent activities and that she was terminated because of this activity. See Mot.
Summ. J., Ex. 15, Pl.’s Interrog. Resp. No. 9. She proffered five instances of protected activity:
•

(1) on December 5, 2014, she e-mailed Camila Campo, Cortes, and Burton about
“unallowable transactions” on a sub-award contract;

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(2) in early December 2014, she notified McDermott and Campo about
unallowable postings regarding “transactions to projects whose award documents
were not issued yet”;

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(3) on January 29, 2015, she “requested documentation” from Koki Hurley,
Cortes, and Burton “to justify $124,000 in unallowable expenses charged to
USAID”;

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(4) in late January, she gave Burton a document titled “fraud indicators” which
displayed a number of UNF’s activities that “fell within the definition of fraud”;
and

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(5) on February 4, she met with Burton and Lara Sonti, Senior Director for
Business Services and Contracts, to discuss “concerns about UNF’s project teams
posting unallowable charges on the contract with USAID.” Id.

During the week of February 2, 2015, Hurley and Omwenga had a lengthy e-mail
exchange about how their roles coexisted on compliance issues, as well as some missing
documents. See Pl. Resp. to Def.’s SOF ¶ 63; Pl. Resp. to Mot. Summ. J., Ex. 30–31, E-Mail
Exchange. Hurley told Burton that Omwenga was unhelpful, accusatory, and condescending.
See Pl. Resp. to Def.’s SOF ¶¶ 62–65. On February 4, 2015, Burton and Richard Parnell, UNF’s
Chief Operating Officer, met to discuss the issue, as well as Omwenga’s communication style

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generally. Id. ¶¶ 67–72. Burton contends that the meeting was focused on ways to improve
Omwenga’s communication style, not the compliance issues she had raised in the e-mail. Id.;
Def.’s Mot. Summ. J., Ex. 2, Burton Dep. at 230–234. Burton further contends that, other than
the issue of Omwenga’s tone in the e-mails and the concerns he claims were voiced at her
performance review in November, UNF did not tell Omwenga to address problems with her
communication skills. See Def.’s Mot. Summ. J., Ex. 2, Burton Dep. at 229–234. In early
February, as a follow up to their meeting, Parnell told Burton to take Omwenga offsite to discuss
ways he could help her succeeded at UNF. See Pl. Resp. to Def.’s SOF ¶ 70.
Following the meeting between Burton and Parnell, Burton and Sonti took Omwenga to
lunch on February 3, 2015. Id. ¶ 71. Burton contends that the purpose of the lunch was to
explain to Omwenga that she could be useful to the Mobile Hub team, and that they did not
discuss the concerns Omwenga had raised in her e-mail exchange with Hurley. Ex. 26, Def.’s
Second Interrog. Resp. No. 15 at 1–3. Omwenga, however, claims that they talked about the
issues in the e-mail exchange, which included concerns about fraudulent charges and reporting
errors. See Pl. Resp. to Def.’s SOF ¶ 72. Omwenga also claims that, although Sonti was not
officially “in-house counsel,” Omwenga viewed her as such because Sonti had a law degree and
was trained as a lawyer. Id. ¶ 72.
On February 4, 2015, Parnell spoke with Kawanna Jenkins in Human Resources to learn
more about Burton’s “working relationship” with Omwenga. Id. ¶ 73. He explained to Jenkins
that “there are other[] [employees] who are complaining about working with [Omwenga].” Id.
¶ 74. After the meeting, and aware that employees had complained about Omwenga, Jenkins
suggested to Burton that Omwenga participate in communications coaching. Id. ¶¶ 74–76.
Burton claims that he did not follow up on this suggestion because he felt UNF reserved

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coaching for people who would be receptive or would advance in the company, and he was
unsure if Omwenga met those criteria. See Def.’s Mot. Summ. J., Ex. 2, Burton Dep. at 283–87.
The UNF employee handbook indicates that “coaching” precedes disciplinary action and that
verbal counseling is the first formal disciplinary step in the “Conflict Resolution and Progressive
Discipline” guidelines. Pl. Resp. to Mot. Summ. J., Ex. 44, UNF handbook at 1. The handbook
guidelines note that, following verbal counseling, a “Written Warning, Decision-Making Leave,
and Investigation Suspension” were the appropriate steps in the disciplinary process. Id. at 1–2.
Omwenga did not receive any disciplinary action other than verbal counseling before she was
terminated.
On February 5, 2015, Burton spoke with Omwenga about her communication skills and
tone. Pl. Resp. to Def.’s SOF ¶ 78. In an e-mail to Jenkins, Burton noted that the meeting went
well, that Omwenga recognized that there were difficulties with the Mobile Hub team and she
had explained that she sometimes felt disrespected by the team, and that she had a good working
relationship with UNF’s other teams. Id. ¶¶ 79–80; Def.’s Mot. Summ. J., Ex. 29, UNF 1417.
Omwenga and Burton agreed to go over talking points and tone suggestions before the next
Mobile Hub monthly meeting. Pl. Resp. to Def.’s SOF ¶¶ 81–83.
On February 11, 2015, Burton and Omwenga met before the monthly meeting to set
communication expectations. Id. ¶ 83. Burton claims that at the meeting Omwenga raised her
voice and did not communicate effectively, although he could not remember specifically what
she did or said. See id. ¶ 84; Def.’s Mot. Summ. J., Ex. 2, Burton Dep. at 297–300. Others at the
meeting also said that Omwenga was rude and condescending and interrupted Burton and
Hurley, forcing Burton to call a “timeout” at the meeting. Def.’s Mot. Summ. J., Ex. 30, Erbrick
Decl. ¶¶ 3–6. Burton, however, indicated it was a combination of Omwenga and McDermott’s

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comments that caused the “timeout.” See Pl. Resp. to Def.’s SOF ¶¶ 84–89; Def.’s Mot. Summ.
J., Ex. 2, Burton Dep. at 215:9–216:10.
The following day, Burton met with Jenkins and told her he wanted to fire Omwenga
based on her behavior. Pl. Resp. to Def.’s SOF ¶ 90–91; Def.’s Mot. Summ. J., Ex. 2, Burton
Dep. at 291–293. Omwenga disputes that Burton’s decision was motivated by her behavior,
noting that Nicolas Bacon, a UNF Executive Director, testified at his deposition that the only
employee he could recall being terminated from UNF without it following the disciplinary policy
in the employee handbook (or at least without a written warning) was an employee who engaged
in years of bullying. See Pl. Resp. to Def.’s SOF ¶ 91. Omwenga also alleges that the
termination conversation between Burton and Jenkins occurred the same day that Omwenga emailed Burton, Hurley, and McDermott about consultants’ conflicts of interest and unallowable
costs charged to USAID. Id. UNF terminated Omwenga on February 18, 2015. Id. ¶ 92.
II. LEGAL STANDARD
Summary judgment is appropriate when there is no disputed genuine issue of material
fact, and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a); Celotex
Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). A dispute of fact is “genuine” only “if the
evidence is such that a reasonable jury could return a verdict for the nonmoving party.”
Anderson v. Liberty Lobby, 477 U.S. 242, 248 (1986). A dispute is “material” only when it
involves facts “that might affect the outcome of the suit under the governing law.” Id. In
determining whether a genuine issue of material fact exists, the court must view all facts in the
light most favorable to the nonmoving party. See Matsushita Elec. Indus. Co. v. Zenith Radio
Corp., 475 U.S. 574, 587 (1986). The moving party “bears the initial responsibility of informing
the district court of the basis for its motion, and identifying those portions of the ‘pleadings,

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depositions, answers to interrogatories, and admissions on file, together with the affidavits . . . ’
which it believes demonstrate the absence of a genuine issue of material fact.” Celotex Corp.,
477 U.S. at 323. In response, the nonmoving party must “go beyond the pleadings” and identify
specific facts which show there is a genuine issue for trial. Id. at 324. To preclude summary
judgment, the nonmovant must “provide evidence that would permit a reasonable jury to find [in
his favor].” Laningham v. U.S. Navy, 813 F.2d 1236, 1242 (D.C. Cir. 1987) (citations omitted).
In evaluating a motion for summary judgment, “the judge’s function is not . . . to weigh
the evidence and determine the truth of the matter but to determine whether there is a genuine
issue for trial.” Liberty Lobby, 477 U.S. at 249. The court must “eschew making credibility
determinations” at the summary judgment stage. Czekalski v. Peters, 475 F.3d 360, 363 (D.C.
Cir. 2017). However, “[i]f the evidence is merely colorable, or is not significantly probative,
summary judgment may be granted.” Liberty Lobby, 477 U.S. at 249–50 (citations omitted).
“[C]onclusory assertions offered without any evidentiary support do not establish a genuine issue
for trial.” Wang v. Wash. Metro. Area Transit Auth., 206 F. Supp. 3d 46, 63 (D.D.C. 2016)
(citing Greene v. Dalton, 164 F.3d 671, 675 (D.C. Cir. 1999)).
III. ANALYSIS
A. Discrimination Claims
Title VII’s anti-discrimination provision prohibits employers from “discriminat[ing]
against any individual with respect to his compensation, terms, conditions, or privileges of
employment, because of such individual’s race, color . . . or national origin.” 42 U.S.C. § 2000e2(a)(1). The DCHRA anti-discrimination provision bars “discrimination by reason of race,
color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation,
gender identity or expression” as well as many other forms of discrimination. D.C. Code

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§ 2.1401.01 et seq. “[I]t is well-established that the DCHRA and Title VII employment
discrimination actions are evaluated under the same legal standard.” Byrd v. District of
Columbia, 807 F. Supp. 2d 37, 58–59 (D.D.C. 2011).
Title VII and DCHRA claims may be proved by direct or circumstantial evidence. See
Brady v. Office of the Sergeant at Arms, 520 F.3d 490, 495 (D.C. Cir. 2008). Where, as here, a
plaintiff has offered indirect evidence of Title VII discrimination, the court applies the familiar
burden-shifting framework articulated in McDonnell Douglas Corp. v. Green, 411 U.S. 792
(1973), to determine whether summary judgment is appropriate. Under that framework, the
plaintiff bears the initial burden of establishing a prima facie case of discrimination. 411 U.S. at
802. In order to do so, a plaintiff must show that: (1) she belongs to a protected class under Title
VII, (2) she experienced an adverse employment action, and (3) the adverse employment action
yields an inference of discrimination. Royall v. Nat’l Ass’n of Letter Carriers, AFL-CIO, 548
F.3d 137, 144 (D.C. Cir. 2008). If the plaintiff meets her burden of establishing a prima facie
case, the burden then shifts to the employer to articulate a legitimate, nondiscriminatory reason
for taking the relevant action. Id. at 144. If an employer proffers such a reason, the burden
reverts to the plaintiff to demonstrate that the employer’s purported justification for the adverse
employment action was merely a pretext for unlawful discrimination. Id.
The D.C. Circuit has determined that the question of whether a plaintiff in a Title VII
discrimination case actually established a prima facie case is “almost always irrelevant.” Brady,
520 F.3d at 493. When “an employee has suffered an adverse employment action and an
employer has asserted a legitimate, non-discriminatory reason for the decision, the district court
need not—and should not—decide whether the plaintiff actually made out a prima facie case

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under McDonnell Douglas.” Id. at 494 (emphasis in original). The summary judgment analysis
instead must focus on “one central question”:
Has the employee produced sufficient evidence for a reasonable jury to find that the
employer’s asserted nondiscriminatory reason was not the actual reason and that the
employer intentionally discriminated against the employee on the basis of race, color,
religion, sex, or national origin?
Id. Recently, this Circuit clarified that Brady’s singular focus on the “pretext” phase of the
McDonnell Douglas analysis is merely a “shortcut” and does not “imply that the District Court
may relieve the employer of its burden, at the second prong, to articulate a legitimate,
nondiscriminatory reason for its action.” Figueroa v. Pompeo, 923 F.3d 1078, 1087 (D.C. Cir.
2019) (internal quotation marks and citation omitted). For the Brady rule to apply, “an employer
at the second prong must proffer admissible evidence showing a legitimate, nondiscriminatory,
clear, and reasonably specific explanation for its actions.” Id. at 1092. The evidence the
employer presents “must suffice to raise a triable issue of fact as to intentional discrimination
and to provide the employee with a full and fair opportunity for rebuttal.” Id.
The D.C. Circuit recently clarified four factors that, in most cases, determine whether an
employer’s evidentiary proffer is adequate: (1) “the employer must produce evidence that a
factfinder may consider at trial (or a summary judgment proceeding)”; (2) if the factfinder
believes the evidence, it “must reasonably be able to find that the employer’s action was
motivated by a nondiscriminatory reason”; (3) the “nondiscriminatory explanation must
be . . . facially credible in light of the proffered evidence”; and (4) the evidence must present a
“clear and reasonably specific explanation” such that the employee has “a full and fair
opportunity to attack the explanation as pretextual.” Id. at 1087–88 (citations and quotation
marks omitted).

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UNF has met its evidentiary burden under the second prong of McDonnell Douglas and
the Figueroa standard as to Omwenga’s Title VII sex discrimination claim (Count VI), her Title
VII racial/national origin discrimination claim (Count V), her Title VII retaliation claim (Count
VII), her DCHRA discrimination claim (Count III), her DCHRA retaliation claim (Count IV)
and her FCA retaliation claim (Count I).
First, because Omwenga has not objected to the admissibility of UNF’s evidence in
support of its motion for summary judgment, the court may consider this evidence. Cf. Ali v.
D.C. Gov’t, 810 F. Supp. 2d 78, 83 (D.D.C. 2011) (“Rule 56 allows a party . . . opposing
summary judgment to object that the material cited to support or dispute a fact cannot be
presented in a form that would be admissible in evidence.”) (citing Fed. R. Civ. P. 56(c)(2))
(quotation marks omitted).
Second and third, a factfinder could reasonably conclude from the evidence that UNF
was motivated by a nondiscriminatory and legitimate reason. See Figueroa, 923 F.3d at 1087.
There is ample evidence that demonstrates Omwenga’s unprofessionalism, poor communication
skills, and lack of significantly superior qualifications for the director-level position. This is
sufficient evidence for a factfinder reasonably to conclude that Omwenga’s qualifications and
performance were the reasons why she was not interviewed for the director-level position and
was terminated.
Fourth, UNF has presented sufficiently clear and specific explanations for not
interviewing Omwenga for the director-level position and for terminating her, such that she has
had “a full and fair opportunity to attack [them] as pretextual.” Id. at 1088. In addition, UNF
has provided specific instances of Omwenga’s alleged poor communication and professionalism,
which “fairly put [her] on notice of what reasoning [she] must challenge,” id. at 1091 (citing

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Stewart v. Ashcroft, 352 F.3d 422, 428 (D.C. Cir. 2003)), and grant her a clear opportunity to
refute UNF’s claims.
Therefore, with respect to those six claims, the burden now reverts to Omwenga to
demonstrate that UNF’s proffered explanations were pretextual. See Royall, 548 F.3d at 144.
Pretext can be shown “either directly by [showing] that a discriminatory [or retaliatory] reason
more likely motivated the employer or indirectly by showing that the employer’s proffered
explanation is unworthy of credence.” Jones v. Bernanke, 557 F.3d 670, 678 (D.C. Cir. 2009).
1. Director Position
UNF offers two non-discriminatory reasons for not interviewing or hiring Omwenga for
the director-level position. First, it contends that it did not hire Omwenga because she did not
meet the minimum qualifications, and she “admitted” to lacking baseline qualifications for the
position. See Def.’s Mot. Summ. J., Ex. 1, Omwenga Dep. at 64. Second, UNF argues that even
if Omwenga was qualified for the position, she was not significantly more qualified than
McDermott or the other interviewed candidates to raise suspicions of discrimination. See
Defendant’s Statement of Facts (“Def.’s SOF”) ¶¶ 14, 16.
Although a reasonable factfinder could conclude that Omwenga demonstrated she was
qualified for the position, see Pl. Resp. to Def.’s SOF ¶ 5, private businesses have discretion with
respect to whom they hire, and Omwenga can show that she was discriminated against only if a
reasonable factfinder could conclude that she was “significantly” more qualified than
McDermott, see Aka v. Wash. Hosp. Ctr., 156 F.3d 1284, 1294 (D.C. Cir. 1998). “If a factfinder
can conclude that a reasonable employer would have found the plaintiff to be significantly better
qualified for the job” then the factfinder can “infer that the employer consciously selected a less-

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qualified candidate—something that employers do not usually do, unless some other strong
consideration, such as discrimination.” Id.
UNF presented evidence that all the candidates they interviewed met the qualifications
for the job posting and that many of these candidates were also minorities. See Def.’s SOF
¶¶ 14, 16. Omwenga, however, failed to provide evidence that would allow a reasonable
factfinder to conclude that she was significantly more qualified than the hired candidate.
2. Omwenga’s Termination
As with her hiring claim, Omwenga must show that UNF’s proffered reasons for why she
was terminated were pretextual. See Royall, 548 F.3d at 144.
Omwenga alleges that once she arrived at UNF, coworkers made nasty, rude, and
unprofessional comments about her. See Pl. Resp. to Def.’s SOF ¶¶ 48, 54. These comments
were primarily made by two employees, one of whom was Axelrod, an Executive Director, and
the other was a member of the Mobile Hub team. Id. Although Omwenga contends that these
comments show UNF’s discriminatory animus, she fails to provide evidence that either of these
employees was authorized to take adverse action against her. Without such evidence, the
statements do not lead to a plausible finding that Omwenga’s termination was motivated by
discriminatory animus.
Therefore, summary judgment will be granted to UNF as to Omwenga’s discrimination
claims (Counts III, V, and VI).
B. Title VII and DCHRA Retaliation Claims
Title VII’s anti-retaliation provision makes it unlawful for an employer “to discriminate
against [an] employee [] . . . because [s]he has opposed any practice” prohibited by Title VII or
“has made a charge, testified, assisted, or participated in” a Title VII proceeding. 42 U.S.C.

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§ 2000e-3(a); see also Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 56 (2006). “The
analysis of [a] claim of retaliation under Title VII applies equally to [a] claim under the
DCHRA.” Cole v. Boeing Co., 75 F. Supp. 3d. 70, 83 (D.D.C. 2014).
For Omwenga to prevail on her retaliation claim, she must “show: (1) that [she] opposed
a practice made unlawful by Title VII; (2) that the employer took a materially adverse action
against [her]; and (3) that the employer took the action ‘because’ the employee opposed the
practice.” McGrath v. Clinton, 666 F.3d 1377, 1380 (D.C. Cir. 2012). This third element means
that Omwenga must show that she would not have been terminated but-for opposing a practice
prohibited by Title VII. See Nunnally v. District of Columbia, 243 F. Supp. 3d 55, 67 (D.D.C.
2017) (holding that “[t]o demonstrate causation in a Title VII or DCHRA case, traditional
principles of but-for causation apply”) (internal quotation marks omitted).
As with discrimination claims, the court utilizes the McDonnell Douglas burden-shifting
framework to analyze retaliation claims. McGrath, 666 F.3d at 1383. Similarly, at the summary
judgment phase, and after the defendant proffers a legitimate, non-retaliatory reason for the
adverse employment action, whether the plaintiff established a prima facie case is irrelevant. See
Cruz v. McAleenan, 931 F.3d 1186, 1194 (D.C. Cir. 2019) (citations omitted); Wiley v.
Glassman, 511 F.3d 151, 156 (D.C. Cir. 2007). Because the court has already found that UNF
proffered legitimate, non-retaliatory reasons for the adverse employment action, the burden shifts
to Omwenga to show that the proffered reasons were pretextual. See Cruz, 931 F.3d at 1193–95.
Omwenga alleges that she was fired because she told Maxine Somerville, the HR
Director, that she was experiencing disparate treatment: she was the only employee and the only
non-Caucasian reporting to Burton who did not have the title of director. See Pl. Resp. to Def.’s

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SOF ¶ 37. However, the only evidence that Omwenga proffers in support of her retaliation claim
is the short period of time between when she raised her concerns and her termination. Id.
Omwenga complained to Somerville on December 11, 2014. Id. ¶ 37. On January 7,
2015, Somerville spoke to Burton about the matter. Id. ¶ 39. A few weeks later, Omwenga emailed Somerville again to inform her that she had talked to Burton about her disparate
treatment. Id. ¶ 37. Omwenga was terminated on February 18, 2015. Id. ¶ 92.
Although alleging mere proximity may be enough to survive a motion to dismiss, see
Hamilton v. Geithner, 666 F.3d 1344, 1357 (D.C. Cir. 2012), more is required at the summary
judgment phase. See Woodruff v. Peters, 482 F.3d 521, 530 (D.C. Cir. 2007); see also Durant v.
D.C. Gov’t, 875 F.3d 685, 700 (D.C. Cir. 2017) (“Where . . . an employer has provided a
legitimate, nonretaliatory reason for its employment action, positive evidence beyond mere
proximity is required to defeat the presumption that the proffered explanation is genuine.”)
(quotation marks and citation omitted). Because Omwenga proffers no evidence beyond the
close in time argument to substantiate her Title VII and DCHRA retaliation claims (Counts IV
and VII), the court will grant UNF’s motion for summary judgment as to these claims.
C. FCA Retaliation Claim
Omwenga claims that UNF violated the FCA’s anti-retaliation provision because she
engaged in the aforementioned protected activity (Count I). The anti-retaliation provision of the
False Claims Act states:
Any employee who is discharged, demoted, suspended, threatened, harassed, or in
any other manner discriminated against in the terms and conditions of
employment by his or her employer because of lawful acts done by the employee
on behalf of the employee or others in furtherance of an action under this section,
including investigation for, initiation of, testimony for, or assistance in an action
filed or to be filed under this section, shall be entitled to all relief necessary to
make the employee whole.

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31 U.S.C. § 3730(h). To establish a retaliation claim under the FCA, Omwenga must
demonstrate “(1) that [she] engaged in protected activity (‘acts done ... in furtherance of an
action under [the FCA]’); and (2) that [she] experienced discrimination ‘because of’ [her]
protected activity.” Shekoyan v. Sibley Int’l, 409 F.3d 414, 422 (D.C. Cir. 2005) (quoting 31
U.S.C. § 3730(h)). “Boiled down to its essentials, an FCA retaliation claim requires: (1)
protected activity; (2) notice; and (3) adverse action taken in response to such protected activity.”
Pitts v. Howard Univ., 111 F. Supp. 3d 9, 17 (D.D.C. 2015).
The court again uses the McDonnell Douglas burden-shifting framework to analyze the
FCA retaliation claim. United States ex rel. Schweizer v. Océ N.V., 677 F.3d 1228, 1240–41
(D.C. Cir. 2012). “Under McDonnell Douglas, an employee first must make out a prima facie
case of retaliation,” and “[i]f the employee does so, then the burden shifts to the employer to
produce admissible evidence that, if believed, would establish that [its] action was motivated by
a legitimate, nondiscriminatory reason.” Id. (internal quotation marks and citations omitted)
(alteration in original). Then, “the burden-shifting framework disappears, and a court reviewing
summary judgment looks to whether a reasonable jury could infer . . . retaliation from all the
evidence.” Id. at 1241 (internal quotations marks omitted).
The court has already found that UNF has provided a sufficient non-retaliatory basis for
Omwenga’s termination. Therefore, the only remaining issue is whether Omwenga has produced
enough evidence such that a reasonable factfinder could infer retaliation; the evidence should
raise “a material dispute on the ultimate issue of retaliation.” Boone, 64 F. Supp. 3d 216, 232
(D.D.C. 2014) (citation omitted). “[T]he Court must review each of the three relevant categories
of evidence—prima facie, pretext, and any other—to determine whether they either separately or

17

in combination provide sufficient evidence for a reasonable jury to infer retaliation.” Id.
(internal citations and quotation marks omitted).
On this “ultimate question, the prima facie case remains relevant, but only as part of the
evidence the court considers.” Gonda v. Donahoe, 79 F. Supp. 3d 284, 294 (D.D.C. 2015)
(citations omitted). Regarding the first of the three categories of evidence, as described below,
Omwegna has established a prima facie case. The D.C. Circuit has interpreted “protected
activity,” the first element of a prima facie case, broadly. See United States ex rel. Yesudian v.
Howard Univ., 153 F.3d 731, 741 (D.C. Cir. 1998). The second and third elements require “that
the employer had knowledge of the employee’s protected activity and that the retaliation was
motivated by the protected activity.” Shekoyan, 409 F.3d at 422. A plaintiff must also show that
in disclosing the possible FCA violations, she was not “merely acting in accordance with [her]
employment obligations to put [her] employers on notice.” United States ex rel. Williams, 389
F.3d at 1261 (internal quotation omitted).
As to the first element of the prima facie case, for Omwenga to show that she was
engaging in protected activity, she must have tried to prevent a false claim (or something that
could reasonably be suspected to be a false claim) from occurring. See id. at 1261 (“Congress
intended to protect employees while they are collecting information about a possible
fraud. . . . Thus, it is sufficient that a plaintiff be investigating matters that reasonably could lead
to a viable False Claims Act case.”) (internal quotation marks and citations omitted). Omwenga
asserts that on five separate occasions she reported impermissible fund allocation and possible
fraud indicators to various UNF employees, and that this was protected activity. See Mot.
Summ. J., Ex. 15, Pl.’s Interrog. Resp. No. 9; Mot. Summ. J., Ex. 16.

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The first such occasion Omwenga alleges was her discussion with Burton and Sonti about
the “fraudulent charges” on a Mobile Hub Project document that was submitted for government
reimbursement. See Pl. Resp. to Def.’s SOF ¶ 72; Pl. Resp. to Mot. Summ. J., Ex. 1, Omwenga
Dep. at 295:6–298:5. The document detailed $124,000 in non-existent contract work that was
expensed to USG funding, and specifically outlined penalties for false or fraudulent submissions.
See Pl. Resp. to Def.’s SOF ¶ 72; Pl. Resp. to Mot. Summ. J., Ex. 1, Omwenga Dep. at 289:12–
22. “‘[S]everal courts have said that internal reporting of false claims is itself an example of a
protected activity’ that can give rise to an FCA retaliation action.” Pencheng Si v. Laogai
Research Found., 71 F. Supp. 3d 73, 99 (D.D.C 2014) (quoting United States ex rel. Yesudian,
153 F.3d at 741 n.9). Because her actions in reporting possible false claims on a project for
which she was not ultimately responsible are akin to an investigation, and separate from her
normal job duties, the court finds that Omwenga has proffered sufficient evidence that she
engaged in protected activity.
Consistent with the reasoning above, Omwenga’s other complaints about improprieties
are also protected. First, on December 5, 2014, she e-mailed Campo, Cortez, and Burton and
explained that a sub-award was expensing funds for items unrelated to the project. See Mot.
Summ. J., Ex. 15, Pl.’s Interrog. Resp. No. 9; Mot. Summ. J., Ex. 16. Second, around early
December 2014, she e-mailed McDermott and Campo and told them they were not allowed to
post transactions to projects whose award documents were not yet issued. See Mot. Summ. J.,
Ex. 15, Pl.’s Interrog. Resp. No. 9. Third, on January 29, 2015, Omwenga e-mailed Hurley,
Cortes, and Burton, asking them to justify $124,000 in unallowable expense charged to USAID.
Id. Finally, on January 29, she gave Burton a document highlighting possible indications of
fraud. See id.; Pl. Resp. to Mot. Summ. J., Ex. 1 at 298:1–303:13.

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In each instance, Omwenga either went outside of her normal chain of command to
express concerns with UNF’s use of government funds or reported possible wrongdoing
regarding a project for which she was not ultimately responsible. See Pl. Resp. to Mot. Summ. J.
Ex. 22, UNF Org. Chart. These actions are enough to show that she engaged in protected
activity.
Second, UNF was aware that Omwenga had been reporting potentially improper activity.
An employer has been put on notice that its employee engaged in protected activity when “a
reasonable factfinder could conclude that . . . the company was on notice that litigation [was] a
reasonable possibility.” United States ex rel. Williams, 389 F.3d at 1262 (internal quotation
marks and citations omitted.) Normally, it is fairly simple to show that an employer has been
notified that an employee engaged in protected activity, but when the employee works in
compliance, as did Omwenga, the task may be more difficult. See id. at 1261 (“[W]ithout
evidence that [the employee] expressed any concerns to his superiors other than those typically
raised as part of a contract administrator’s job, an employer could not be on notice that the
employee was acting in furtherance of an FCA action.”) (internal quotation marks omitted)
(alteration in original). Therefore, the employee “must overcome the presumption that [she is]
merely acting in accordance with [her] employment obligations to put [her] employer[] on
notice.” Id. “[W]hen an employee acts outside [her] normal job responsibilities or alerts a party
outside the usual chain of command, such action may suffice to notify the employer that the
employee is engaging in protected activity.” Id. The evidence adduced shows that Omwenga
notified UNF of her protected activity in both ways, i.e., by acting outside her normal job
responsibilities and alerting a party outside the usual chain of command.

20

The evidence, viewed in the light most favorable to Omwenga, shows that she notified
UNF of her protected activity when she reported potential FCA issues stemming from the Mobile
Hub project, because she was not ultimately responsible for the compliance work on that project.
See Pl. Resp. to Def.’s SOF ¶ 46; Pl. Resp. to Mot. Summ. J., Ex. 20, Axelrod Dep. at 169:3–
169:11. Therefore, because all five instances of Omwenga’s protected activity stemmed from
the Mobile Hub project, a reasonable factfinder could determine that her disclosures were outside
of her job responsibilities, and that UNF could reasonably expect litigation as a result of her
reported activity.
Moreover, Omwenga provided evidence that she alerted UNF employees outside her
chain of command—such as Campo, Cortes, Sonti, and Hurley—about her protected activity.
See Mot. Summ. J., Ex. 15, Pl.’s Interrog. Resp. No. 9; Pl. Resp. to Mot. Summ. J., Ex. 22, UNF
Org. Chart. Because she did so, and because this deviation from the chain of command is also
enough to give an employer notice that an employee is engaging in protected activity, a
reasonable factfinder could conclude that UNF was notified of Omwenga’s protected activity.
See United States ex rel. Williams, 389 F.3d at 1261.
As to the third element of a prima facie case, a finder of fact could reasonably conclude
that Omwenga’s protected activity was a cause of her termination. Causation requires that “the
retaliation was motivated, at least in part, by the employee’s engaging in [that] protected
activity.” United States ex rel. Yesudian, 153 F.3d at 736. In other words, a “plaintiff is required
to produce evidence of retaliation sufficient for a reasonable jury to conclude that [her] protected
activity was a contributing factor in the alleged prohibited personnel action.” Payne v. District
of Columbia, 722 F.3d 345, 353 (D.C. Cir. 2013). “In assessing the causal link between
protected activity and a relator’s termination, courts often consider the temporal proximity

21

between the employer’s notice of the conduct and the relator’s termination.” Pencheng Si, 71 F.
Supp. 3d at 102. Viewing the facts in the light most favorable to Omwenga, the court determines
that all her protected activity occurred within three months of her termination, with the most
recent occurring two weeks before she was fired, when she discussed instances of fraudulent or
misallocated spending by UNF. See Def.’s Mot. Summ. J., Ex. 15, Pl.’s Interrog. Resp. No. 9.
Omwenga also claims that UNF’s stated reasons for her termination are pretextual. First,
she contends UNF deviated from its employee handbook’s discipline guidelines. See Pl. Resp. to
Def.’s SOF ¶¶ 60, 77. “[A]n employer’s violation of its own procedures can be evidence of
pretext.” Greer v. Paulson, 505 F.3d 1306, 1319 (D.C. Cir. 2007); see also Jones v. Ottenberg’s
Bakers, Inc., 999 F. Supp. 2d 185, 191 (D.D.C. 2013) (“[D]eviations from standard procedures
may . . . give rise to an inference of pretext at the summary-judgment stage.”) (quotation marks
and citations omitted). However, courts tend to give less weight to employer’s non-adherence to
an internal discipline policy when such adherence is not required. See Long v. Endocrine Soc’y,
263 F. Supp. 3d 275, 286 (D.D.C. 2017).
There is no evidence in the record that Omwenga was verbally counseled about her
communication and professionalism skills, or disciplined in any manner until February 5, 2015, a
week before she was fired. See Pl. Resp. to Def.’s SOF ¶¶ 48–49, 58, 60, 78. This is
inconsistent with the “Conflict Resolution and Progressive Discipline” guidelines in the UNF
employee handbook, which encourage UNF to work with employees. See Pl. Resp. to Mot.
Summ. J., Ex. 44 UNF handbook at 1. Moreover, Burton did not refer Omwenga for coaching,
even when it was suggested by the HR director. Pl. Resp. to Def.’s SOF ¶¶ 75–77; see Def.’s
Mot. Summ. J., Ex. 2, Burton Dep. at 283–87. Under the terms of the UNF employee handbook,
coaching is a precursor to disciplinary action. See Pl. Resp. to Mot. Summ. J., Ex. 44 UNF

22

handbook at 1. Omwenga was also not given a written warning, decision-making leave, or an
investigation suspension, all of which are suggested disciplinary actions if an employee must be
disciplined after verbal counseling. See Pl. Resp. to Def.’s SOF ¶ 91; Pl. Resp. to Mot. Summ.
J., Ex. 44 UNF handbook at 1. Although these actions are not mandatory, Nicolas Bacon, a UNF
Executive Director, testified at his deposition that, other than an employee who engaged in years
of bullying behavior, Omwenga was the only employee he could recall being terminated from
UNF without it following the handbook’s disciplinary policy. Pl. Resp. to Def.’s SOF ¶ 91.
Omwenga also argues that UNF’s stated reason for disciplining and ultimately firing her
was pretextual, because, although UNF employees had previously complained about her
communication and professionalism skills, she was verbally disciplined by Burton two days after
she told him and Sonti about her protected activity at lunch. Other courts have found pretext in
retaliation cases when an employer disciplined an employee only after she engaged “in
protect[ed] activity, even though [the employee] had not been disciplined for engaging in similar
activity prior to her protected activity.” See, e.g., Williams v. Ricoh Americas, Corp., 203 F.
Supp. 3d 692, 698 (E.D. Va. 2016).
Therefore, considering Omwenga’s prima facie case and her evidence of pretext, the
court concludes that a reasonable factfinder could infer retaliation, and UNF’s motion for
summary judgment with respect to the FCA retaliation claim (Count I) will be denied.
D. NDAA Retaliation Claim
Omwenga alleges that after reporting to her superiors and co-workers about possible
gross mismanagement of government grants and/or illegal activity regarding grant money, UNF
terminated her, in violation of the NDAA’s anti-retaliation provision, 41 U.S.C. § 4712, (Count
VIII). The NDAA states:

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An employee of a contractor, subcontractor, grantee, or subgrantee or personal services
contractor may not be discharged, demoted, or otherwise discriminated against as a
reprisal for disclosing to a person or body described in paragraph (2) information that the
employee reasonably believes is evidence of gross mismanagement of a Federal contract
or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal
contract or grant, a substantial and specific danger to public health or safety, or a
violation of law, rule, or regulation related to a Federal contract (including the
competition for or negotiation of a contract) or grant.
41 U.S.C. § 4712(a)(1). To establish retaliation under § 4712, a plaintiff must show “that (1) she
was an employee of a government contractor, (2) she disclosed information that she reasonably
believed was evidence of a rule violation related to a federal contract to the required person, and
(3) her disclosure was a contributing factor in the action taken against her.” Armstrong v.
Arcanum Grp. Inc., 2017 WL 4236315, at *7 (D. Colo. Sept. 25, 2017). In Armstrong, the court
stated:
The NDAA does not follow McDonnell Douglas, but incorporates a similar framework
into the statute itself by borrowing from an administrative-law statute. 41 U.S.C.
§ 4712(c)(6) provides that the legal burdens in 5 U.S.C. § 1221(e) shall be controlling for
any judicial determination of whether retaliation occurred. [Section] 1221(e), in turn,
requires that an employee show her protected activity was a “contributing factor” in the
employment action taken unless the agency . . . “demonstrates by clear and convincing
evidence that it would have taken the same personnel action” without disclosure. Thus,
the questions asked are similar, but the NDAA collapses the McDonnell Douglas stages
into a single question that the employer can only surmount with clear and convincing
evidence as opposed to a preponderance of the evidence.
Id. Viewing the evidence in the light most favorable to Omwenga, the court finds that a
disinterested observer with knowledge of the essential facts could conclude that Omwenga
believed she was reporting gross mismanagement. Omwenga alleged that UNF charged
“$124,000 [] to USAID for the Mobile Hub Project,” Pl. Resp. to Mot. Summ. J., Ex. 1,
Omwenga Dep. 289:16–22, and that “107,892.27 [was] charged to consultant’s fees” for which
there was no documentation, id. Ex. 50, UNF 1118; see also Ex. 51, UNF 1953. Because this
court has already found that a reasonable factfinder could find retaliation for the same

24

disclosures under the FCA, see supra Section III, C., a reasonable factfinder could find “her
disclosure was a contributing factor in the action taken against her” as required by NDAA. See
Armstrong, 2017 WL 4236315, at *7.
UNF contends that Omwenga’s claim under the NDAA fails because her disclosures
were not made to the “required person.” Id. Under the statute, disclosures must be made to a
“management official or other employee of the . . . grantee who has the responsibility to
investigate, discover, or address misconduct.” 41 U.S.C. § 4712(a)(2)(G). Omwenga concedes
that that she did not report her concerns to Rick Parnell, the Chief Operating Officer, to whom
supervisors and managers were required to bring concerns of suspected fraud and legal
violations. Pl. Resp. to Def.’s SOF ¶ 98; see Def.’s Mot. Summ. J., Ex. 44, UNF handbook at
1054. However, the UNF handbook also states that an individual’s “immediate supervisor is in
the best position to address an area of concern.” Def.’s Mot. Summ. J., Ex. 44, UNF handbook
at 1054. As laid out in the FCA portion of this opinion, Omwenga brought her concerns to her
supervisor, Burton, at the February 4 lunch. See Mot. Summ. J., Ex. 15, Pl.’s Interrog. Resp. No.
9. Therefore, the court finds that a reasonable factfinder could conclude that she was fired for
reporting what she believed to be gross mismanagement of a federal contract, and summary
judgment will be denied to UNF with respect to Omwenga’s NDAA Retaliation Claim (Count
VIII).
E. Wrongful Discharge
Finally, Omwenga alleges that she was discharged in violation of the public policy
protections embedded in District of Columbia common law (Count II).
“[I]n the District of Columbia . . . an employer may discharge an at-will employee at any
time and for any reason, or for no reason at all.” Adams v. George W. Cochran & Co., 597 A.2d

25

28, 30 (D.C. 1991) (citations omitted). However, there is a very narrow public policy exception
to this general rule. Id. at 34. “An exception warrants recognition if it is firmly anchored either
in the Constitution or in a statute or regulation which clearly reflects the particular ‘public
policy’ being relied upon and there is a close fit between the policy thus declared and the
conduct at issue in the allegedly wrongful termination.” Herron v. Fannie Mae, 861 F.3d 160,
170 (D.C. Cir. 2017) (quotation marks and citation omitted) (footnote omitted).
Omwenga advances two theories in support of a public policy exception: (1) her reports
of gross fund mismanagement and (2) her disclosures of conflicts of interest. First, she cites 5
U.S.C. § 2302(8)(A), which outlines “prohibited personnel activity,” including “tak[ing] . . . a
personnel action . . . because of any disclosure of information by an employee . . . which the
employee reasonably believes evidences . . . gross mismanagement [or] a gross waste of
funds . . . .” In support of her second theory, she relies on 48 C.F.R. 3.101–1, which states “the
general rule is to avoid strictly any conflict of interest or even the appearance of a conflict of
interest in Government-contractor relationships.”
UNF argues, that, as a threshold matter, these laws do not apply to it as a government
“grantee.” See Def.’s Mot. Summ. J. at 22–23. This argument is unavailing because it does not
address the pertinent question: whether the statute and regulation “clearly reflect a policy
prohibiting the activity about which the employee complained.” Leyden v. American
Accreditation Healthcare Comm’n, 83 F. Supp. 3d 241, 249 (D.D.C. 2015). Section 2302(8)(A)
clearly reflects a public policy against gross mismanagement of funds by including it under
“prohibited activity.” The regulation establishes a policy against conflicts of interest by
establishing the “general rule [of] strict[]” avoidance. Cf. Liberatore v. Melville Corp., 168 F.3d
1326, 1331 (D.C. Cir. 1999) (recognizing a public policy exception when an employee was

26

terminated after notifying the employer of a violation of “legal proscriptions” surrounding food
and drug regulations). Even if UNF is merely a “grantee,” both the statute and the regulation are
concerned with the use of government funds. Because Omwenga’s reports about
mismanagement and conflicts were based on UNF’s use of the USAID grant, see Mot. Summ. J.,
Ex. 15, Pl.’s Interrog. Resp. No. 9, which is funding from a government agency, the statute and
regulation clearly address Omwenga’s reports.
However, to survive summary judgment on a claim of wrongful discharge in violation of
public policy, Omwenga must show, inter alia, that a reasonable jury could find that she was
terminated “at least predominat[ly]” in contravention of either public policy exception. Bereston
v. UHS of Del., Inc., 180 A.3d 95, 104 (D.C. 2018). Because the court has already found that a
reasonable jury could find retaliation for the same disclosures under NDAA, see supra Section
III, D, a reasonable jury could find she was terminated in contravention of the public policy
against “gross fund mismanagement” under § 2302(8)(A). With respect to Omwenga’s second
public policy exception, based on 48 C.F.R. 3.101–1, no reasonable jury could find that she was
terminated predominantly for disclosing conflicts of interest, when the uncontroverted evidence
is that Omwenga only discussed the alleged conflicts once with her superior, Burton. See Pl.
Resp. to Mot. Summ. J., Ex. 53, UNF 897. However, because, as noted above, a reasonable jury
could conclude that Omwenga was terminated predominantly for her reports of gross
mismanagement, summary judgment will be denied to UNF on the Wrongful Discharge Claim
(Count II).

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IV. CONCLUSION
For the reasons stated above, UNF’s motion for summary judgment will be granted in
part and denied in part. The motion will be granted with respect to Counts III, IV, V, VI, and
VII, and it will be denied with respect to Counts I, II, VIII.
A corresponding Order will issue separately.
Date: September 30, 2019

Tanya S. Chutkan

TANYA S. CHUTKAN
United States District Judge

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