Walker v. Secretary of Treasury, IRS

Tracy Walker (plaintiff), a light-skinned Black woman, worked as a typist in the Atlanta office of the Internal Revenue Service (IRS) (defendant). Walker had a strained relationship with her supervisor, Ruby Lewis, who was a dark-skinned Black woman. Walker believed that Lewis subjected her to increased scrutiny and reprimanded her for false or insubstantial infractions due to personal hostility toward Walker’s lighter skin. Walker met with the equal-employment-opportunity-program manager for the IRS’s Atlanta district to discuss Lewis’s conduct. Two weeks later, Walker was terminated based on a recommendation from Lewis citing tardiness, laziness, incompetence, and attitude problems. Walker sued the IRS for, among other things, violation of Title VII of the Civil Rights Act of 1964 (Title VII), arguing that she was terminated because of Lewis’s color-based discrimination and that her termination constituted retaliation for reporting Lewis’s discriminatory conduct. The IRS argued that color-based discrimination was synonymous with race-based discrimination and that Walker’s discrimination claim therefore failed because both Walker and Lewis were Black. The district judge referred the case to a magistrate, who recommended, among other things, granting summary judgment to the IRS regarding the Title VII discrimination claim but denying summary judgment as to the retaliation claim. The district court reviewed the magistrate’s recommendation.