Holmes v. Drug Enforcement Administration
Plaintiff Cheryl Holmes sued her employer, the Drug Enforcement Administration (DEA), alleging employment discrimination based on sex and age, retaliation, hostile work environment, and constructive discharge under Title VII and the ADEA. Holmes claimed she was discriminatorily rotated from her Chief of Research and Analysis Section position, reassigned to "menial and degrading jobs," and forced into retirement. The Court granted the DEA's motion to dismiss or for summary judgment, finding that Holmes failed to exhaust administrative remedies for some claims, did not establish a prima facie case of gender or age discrimination due to lack of adverse employment action and similarly situated comparators, and failed to prove retaliation or a hostile work environment. The Court also found Holmes did not meet the higher harassment threshold required for constructive discharge.