Miles v. Tennessee Valley Authority

Plaintiff Tameka Miles, an African American female contract specialist with the Tennessee Valley Authority, filed suit alleging race and sex discrimination, a hostile work environment, and retaliation under Title VII and state law. She claimed she faced disparate treatment in performance evaluations, discipline, and ultimate termination after complaining about bias. The United States District Court for the Eastern District of Tennessee granted summary judgment to TVA, finding that Miles failed to demonstrate that the agency’s legitimate, non-discriminatory reasons for its actions were a pretext for discrimination or that retaliation was the but-for cause of her termination. On July 28, 2023, the Sixth Circuit affirmed the decision.

The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of TVA, dismissing all discrimination and retaliation claims.

Whether the plaintiff presented sufficient evidence to create a genuine dispute of material fact that TVA’s stated performance-based reasons were pretext for race and sex discrimination, and whether her termination constituted unlawful retaliation.

The ruling reinforced the high evidentiary bar for plaintiffs to prove pretext and but-for causation in federal employment retaliation cases, providing clearer guidance for federal agencies defending against Title VII claims.