Washington v. Bessent – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the district court's grant of summary judgment against the plaintiff on his Title VII retaliation and hostile work environment claims.
Standard: Summary judgment standard; Title VII retaliation causation; hostile work environment severity
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: The decision reinforces that plaintiffs must provide specific evidence of causation beyond temporal proximity in retaliation cases and that routine performance feedback does not constitute a hostile work environment.

Washington v. Bessent

May 12, 2026 ·3:21-cv-00333-JR ·Unpublished · By Aisha Johnson

The Ninth Circuit affirmed a district court's grant of summary judgment in a Title VII employment dispute. The appellate panel concluded the plaintiff failed to prove causation for retaliation or establish a hostile work environment.

Background

Wilmore Lee Washington III appealed the district court’s grant of summary judgment in favor of the Department of the Treasury. The appeal concerned Title VII retaliation and hostile work environment claims, as well as denials of spoliation sanctions and judicial recusal requests.

The court’s reasoning

The court reviewed the summary judgment grant de novo and found no genuine dispute of material fact. Regarding retaliation, the record showed performance ratings were reduced due to documented case management issues, not the EEO complaint. Temporal proximity alone was insufficient to establish causation. For the hostile work environment claim, the alleged conduct consisted of professional feedback and supervision, which is not severe or pervasive enough to meet the legal standard. The court also affirmed the denial of spoliation sanctions and recusal motions, noting that judicial rulings alone rarely justify recusal.

What it means going forward

The decision reinforces that plaintiffs must provide specific evidence of causation beyond temporal proximity in retaliation cases and that routine performance feedback does not constitute a hostile work environment.