German v. Pena
Plaintiff Alexander German, a Russian native, sued Frederico Pena, Secretary of the U.S. Department of Energy, alleging national origin discrimination under Title VII. German claimed unequal employment terms, failure to promote, and prevention from competing for a promotion at the Environmental Measurements Laboratory (EML). The defendant moved to dismiss for lack of subject matter jurisdiction and failure to state a claim, arguing German failed to exhaust administrative remedies. The court found that German did not contact an EEO counselor within the required 45 days of the alleged discrimination, despite EML providing notice of these procedures. The court rejected regulatory and equitable exceptions, finding German's subjective ignorance of the EEO poster's content incredible and insufficient. The court granted summary judgment in favor of the defendant, dismissing the action with prejudice.