The U.S. Court of Appeals for the Fourth Circuit affirmed a district court's dismissal of a Title VII retaliation claim brought by former postal worker Monica Andrews against Postmaster General Louis DeJoy and the U.S. Postal Service in an unpublished per curiam opinion filed Jan. 9, 2026.
The three-judge panel, consisting of Circuit Judges Wilkinson, Agee, and Thacker, unanimously upheld the lower court's grant of summary judgment in favor of the USPS. The court held that Andrews failed to establish a prima facie case of retaliation under Title VII of the Civil Rights Act of 1964 and could not demonstrate that the agency's stated reasons for her termination were pretextual.
Andrews, a Black woman who has worked for the USPS in various locations since 2017, transferred to Norton, Virginia in November 2019 as a part-time Sales and Services/Distribution Clerk. According to court documents, her legal dispute arose after she filed administrative complaints against her supervisor, alleging that he subsequently retaliated against her in violation of federal employment discrimination laws.
The case originated in the U.S. District Court for the Western District of Virginia at Big Stone Gap, where Senior District Judge James P. Jones presided over the matter. The district court granted summary judgment in favor of the USPS, prompting Andrews to appeal the decision to the Fourth Circuit.
In Title VII retaliation cases, plaintiffs must typically establish a prima facie case by demonstrating that they engaged in protected activity, suffered an adverse employment action, and that there was a causal connection between the protected activity and the adverse action. The employer then has the burden to articulate a legitimate, non-discriminatory reason for the adverse action, after which the plaintiff must prove that the stated reason was merely a pretext for retaliation.
The Fourth Circuit found that Andrews failed to meet these legal standards. The court concluded that she could not establish the essential elements of a prima facie retaliation case and also failed to demonstrate that the USPS's stated reasons for her termination were pretextual - meaning false or used to cover up the real discriminatory motive.
Andrews was represented by A. Marques Pitre of Pitre & Associates, LLC in Washington, D.C. The government was represented by U.S. Attorney C. Todd Gilbert and Assistant U.S. Attorney G. Riley Worrell from the Office of the United States Attorney in Roanoke, Virginia.
The appeal was submitted to the court on Nov. 19, 2025, and decided approximately seven weeks later. The unpublished nature of the opinion means it does not set binding precedent within the Fourth Circuit, which encompasses Maryland, Virginia, West Virginia, North Carolina, and South Carolina.
Title VII retaliation claims have become increasingly common in federal employment discrimination litigation. The law prohibits employers from retaliating against employees who oppose discriminatory practices or participate in discrimination investigations, complaints, or lawsuits. However, courts require plaintiffs to meet specific evidentiary standards to prove their cases.
The USPS, as one of the largest employers in the United States with approximately 650,000 workers, faces numerous employment-related lawsuits each year. The agency has been the subject of various workplace discrimination and retaliation claims as it has worked to modernize its operations and workforce management practices.
Retaliation claims under Title VII can result in various remedies if successful, including reinstatement, back pay, compensatory damages for emotional distress, and attorney's fees. However, plaintiffs must navigate complex legal standards and procedural requirements to prevail in these cases.
The Fourth Circuit's affirmance of summary judgment indicates that the court found the evidence insufficient to create a genuine issue of material fact regarding Andrews' retaliation claims. Summary judgment is appropriate when there are no genuine disputes about material facts and the moving party is entitled to judgment as a matter of law.
This case highlights the challenges that federal employees face when pursuing retaliation claims against their employers. While Title VII provides important protections for workers who report discrimination or participate in related proceedings, courts apply rigorous standards in evaluating these claims to ensure they have merit.
The decision represents another data point in the ongoing body of federal employment discrimination jurisprudence, particularly as it relates to postal service employees and the standards required to prove retaliation in the federal workplace. For Andrews, the unfavorable ruling concludes her legal challenge against the USPS leadership.