Khowaja v. Sessions

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s Title VII action, alleging that defendant’s termination of plaintiff as special agent was improperly based on his Muslim religion. Record showed that plaintiff’s termination followed series of performance evaluations indicating that plaintiff needed improvement on judgment skills based on several incidents in which plaintiff had failed to follow proper procedures. As such, where lack of judgment skills was sufficient to support employee’s termination, plaintiff failed to show that he had met defendant’s legitimate job expectations for purposes of establishing prima facie case of discrimination. Moreover, plaintiff failed to present evidence of suitable comparative co-worker who committed similar infractions and who had received more favorable treatment. Fact that one co-worker committed same infraction on two occasions did not require different result, where plaintiff was lead investigator with respect to one incident, and where co-worker did not have similar volume of infractions as plaintiff. Plaintiff further failed to establish how his Muslim religion otherwise factored into his termination.