Laughlin v. Metropolitan Washington Airports Authority

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.