Quimbee logo
DMCA.com Protection Status
From our private database of 16,500+ case briefs...

Laughlin v. Metropolitan Washington Airports Authority

United States Court of Appeals for the Fourth Circuit
149 F.3d 253 (4th Cir. 1998)


In April 1994, Kathy LaSauce, an employee of Metropolitan Washington Airports Authority (MWAA) (defendant) informed airport manager Augustus Melton of a retaliation charge against LaSauce’s MWAA supervisor, William Rankin. Melton attempted to resolve the complaint informally, but LaSauce ultimately filed a formal complaint and resigned. While investigating the complaint, Melton drafted an informal letter to Rankin, warning Rankin about the alleged inappropriate retaliation against LaSauce. The letter, dated September 8, 1994, was never formalized, signed, or sent to Rankin; it remained on Melton’s desk. Around the same time, Rankin announced he had accepted a job at a different airport and resigned. Laughlin (plaintiff), Melton’s secretary, found the letter to Rankin on Melton’s desk on September 29, 1994. Laughlin concluded Melton had tried to cover up Rankin’s actions and withheld the letter to interfere with LaSauce’s ability to prove retaliation in a future lawsuit. Laughlin removed the letter and several other documents from Melton’s desk, photocopied them, and sent copies to LaSauce. Laughlin’s actions were uncovered in 1996, during LaSauce’s civil suit proceedings. Laughlin was fired for removing and releasing confidential documents without consent. Laughlin sued MWAA, alleging unlawful retaliation under Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. The district court granted summary judgment to MWAA, concluding that deceitful conduct is presumptively unprotected under Title VII. Laughlin appealed.

Rule of Law


Holding and Reasoning (Williams, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 409,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,500 briefs, keyed to 223 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial