D.C. Employment Law Case: N’Samba Ndondji v. Interpark, Inc. (Race Discrimination; National Origin Discrimination; Adverse Employment Actions)


While this District of Columbia federal court opinion deals with several important employment law issues, of particular note is the Court's explanation of: (1) the distinction between race discrimination and national origin discrimination claims; and (2) the test for "adverse employment actions" under Title VII and the D.C. Human Rights Act (DCHRA).

In this case, Mr. Ndondji sued his employer, Interpark, under Section 1981, Title VII and the DCHRA alleging race discrimination, national origin discrimination, and retaliation. By way of background, the DCHRA and Title VII protect employees against race discrimination, national origin discrimination, and other forms of employment discrimination. Section 1981 applies to racial discrimination only.

In dismissing the employee's race discrimination claims, the Court held that Mr. Ndondji had failed to allege facts to establish that alleged discrimination because he was from Angola (national origin) also meant that he had been discriminated against because of his race.

The Court dismissed most of Mr. Ndondji's remaining claims on grounds that the claims were procedurally barred or that Mr. Ndondji had failed to identify any "adverse employment action" taken by his employer that could satisfy the test under Title VII or the District of Columbia Human Rights Act. This was true even though Mr. Ndonji had identified at least five different adverse actions that he believed violated the employment laws.

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