Forman, Paul v. Small, Lawrence M.

                  United States Court of Appeals

               FOR THE DISTRICT OF COLUMBIA CIRCUIT

      Argued September 7, 2001   Decided November 16, 2001 

                           No. 00-5256

                          Paul Forman, 
                            Appellant

                                v.

     Lawrence M. Small, Secretary, Smithsonian Institution, 
                             Appellee

          Appeal from the United States District Court 
                  for the District of Columbia 
                         (No. 96cv02735)

     Stephen Z. Chertkof argued the cause for appellant.  With 
him on the briefs was Douglas B. Huron.

     Diane M. Sullivan, Assistant U.S. Attorney, argued the 
cause for appellee.  With her on the brief were Kenneth L. 
Wainstein, U.S. Attorney, R. Craig Lawrence, Assistant U.S. 
Attorney, and Christine Nicholson, Assistant General Coun-
sel, Smithsonian Institution.

     Before:  Henderson, Randolph and Rogers, Circuit Judges.

     Opinion for the Court filed by Circuit Judge Rogers.

     Rogers, Circuit Judge:  Paul Forman appeals the grant of 
summary judgment to the Smithsonian Institution on his 
claims of age discrimination and retaliation under the Age 
Discrimination in Employment Act ("ADEA"), 29 U.S.C. 
s 633a (1994 & Supp. V 1999).  He contends that he estab-
lished a prima facie case on each of his claims and rebutted 
the Smithsonian's stated explanations for its actions.  We 
affirm the judgment on his claims of discrimination with 
regard to his 1991 and 1995 promotions, but we reverse as to 
his claim of retaliation with regard to his 1995 promotion.

                                I.

     Paul Forman is a curator for Modern Physics at the 
National Museum of American History of the Smithsonian 
Institution.  He was hired in 1972 as an associate curator, 
Grade 12, and received a promotion in 1975 to curator, Grade 
13.  He was passed over for a non-competitive promotion to 
Grade 14 in 1988 and 1991-92.  In 1995, a decision concerning 
his promotion was postponed for one year.  He was promoted 
to Grade 14 in 1996 when he was 59 years old.  The relevant 
background to these decisions is as follows.

     In May 1988, Dr. Forman requested and was granted a 
two-year temporary duty assignment to New York City with 
the primary task of preparing a draft of a book on the history 
of atomic clocks.1  His normal day-to-day duties as curator, 
relating to exhibitions and collections, were minimized.  For 
the rating year September 1, 1988, to August 31, 1989, Dr. 
Forman received a performance appraisal of "fully successful" 
from his supervisor.  In the same performance evaluation, 
however, his supervisor advised Dr. Forman that he expected 
a "concentrated and sustained effort ... during th[e] next 

__________
     1  An "atomic clock" is a clock in which the "periodic process is a 
molecular or atomic event associated with a particular spectral 
line."  A New Dictionary of Physics 94 (H. J. Gray & Alan Isaacs 
eds., 1975).

year on the book project, now that it is underway."  At the 
time, Dr. Forman had only drafted about one-half of a 
chapter, albeit a lengthy one.

     In January 1990, Dr. Forman proposed that the one chap-
ter he had drafted for his book on atomic clocks about 
Charles Townes and the maser 2 become the basis of a 
different, shorter book, narrower in scope than the one he 
had originally committed to write about atomic clocks.  His 
supervisor approved the shorter book.  His interim perfor-
mance appraisal (evaluating only his performance from Sep-
tember 1, 1989 to May 1990 for the evaluation period of 
September 1, 1989 to August 31, 1990), however, was "unac-
ceptable" as to the "single critical element" of his assignment, 
namely to draft a "book-length manuscript."  An accompany-
ing letter from his supervisor, dated May 22, 1990, described 
Dr. Forman's lack of substantial progress on the promised 
book manuscript, focusing on a substantial period of "under 
productivity" in his central assignment, which was the princi-
pal area of his research during the last decade.  In his final 
performance evaluation for the rating period of September 1, 
1989 to August 31, 1990, Dr. Forman received a rating of 
"fully successful";  his supervisor noted that Dr. Forman had 
begun in the latter part of the performance year to produce 
"commendable draft chapters of the Townes and the Maser 
manuscript at a steady pace."  Dr. Forman returned to work 
at the Smithsonian Institution in October 1990.  In the next 
rating year, from September 1, 1990 to August 31, 1991, he 
again received a "fully successful" rating.

     Robert McCormick Adams was the Secretary when Dr. 
Forman was considered for promotion in 1991.  During this 

__________
     2  A "maser" pre-dates the laser, but works under the same 
principle as a laser, with the generated beam occurring in the 
microwave region of the spectrum, which lies between infrared 
radiation and radio waves, rather than, like a laser, in the visible, 
ultraviolet, or infrared regions of the spectrum.  See A New Dictio-
nary of Physics, supra, at 335, 350.  A laser is also known as an 
"optical maser."  Id. at 308.  Masers and atomic clocks are interre-
lated because the oscillations produced by a maser can provide the 
frequency standard for an atomic clock.  Id. at 94.

period, there were six principal features of the promotion 
process for all curators at the National Museum of American 
History.  The Professional Accomplishment Evaluation Com-
mittee, which is a peer evaluation committee of curators 
appointed by the Director of the Museum, considers curators 
at Grade 13 for possible non-competitive promotion every 
three years.  The peer review committee's recommendation is 
advisory to the Director of the Museum.  The Director also 
considered other factors such as annual summary perfor-
mance appraisals as well as the opinions of the curator's 
supervisors.3  The Director made an advisory recommenda-
tion to the Secretary.  The Secretary also customarily re-
ceived advisory recommendations from his Assistant Secre-
taries before making his final decision.  Thus, the Secretary 
had the final authority to make decisions regarding pro-
motions.

     In April 1991, the peer review committee recommended 
Dr. Forman for promotion to Grade 14.  The Director of the 
Museum advised Dr. Forman in June 1991 that in light of 
the fact that none of his supervisors thought he was working 
at a Grade 14 level, and the primacy of a book in his 
performance plan since 1978, Dr. Forman would not be 
recommended for promotion.  The Director nonetheless for-
warded Dr. Forman's promotion package to the Assistant 
Secretary for Research.  The two Assistant Secretaries, Rob-
ert Hoffman and Tom Freudenheim, reviewed Dr. Forman's 
promotion package.  Hoffman recommended to the Secretary 
that Dr. Forman be promoted; Freudenheim recommended 
against promotion.  In March 1992, after reviewing Dr. For-
man's promotion package and discussing the matter with 
both Assistant Secretaries, Secretary Adams decided not to 
promote him, expressing concern that notwithstanding Dr. 
Forman's international reputation as an historian, he had 
failed to produce a book-length manuscript on atomic clocks 

__________
     3  Possible annual performance appraisal ratings were outstand-
ing, highly successful, fully successful, improvement needed, and 
unacceptable.  The evaluations considered several performance ele-
ments including research, collections, exhibits, and public and Muse-
um service.

"or any other work of comparable scope."  Secretary Adams 
decided that consideration of a promotion should be post-
poned until Dr. Forman completed "a major scholarly work 
such as the manuscript on atomic clocks, or his proposed 
biography of Charles Townes, or some other work of his 
choosing."

     During the Secretary's discussion of Dr. Forman's pro-
motion with the Assistant Secretaries, comments were made 
regarding Dr. Forman's age, generally to the effect that he 
might be "beyond his years of scholarly productivity";  Secre-
tary Adams denied making these statements.  Dr. Forman 
filed an administrative complaint of age discrimination on 
May 26, 1992, and upon being denied relief, he filed an 
administrative appeal with the Equal Employment Opportuni-
ty Commission, which was still pending when he was consid-
ered for promotion in 1995.

     When Dr. Forman was next considered for a promotion in 
1995, I. Michael Heyman was the Secretary and Spencer 
Crew was the Director of the National Museum of American 
History.  Secretary Heyman instituted various changes in the 
structure and promotion process of the Museum.  Secretary 
Heyman abolished the positions of Assistant Secretary and 
created in their place the position of Provost.  During Dr. 
Forman's 1995 promotion decision, Robert Hoffman served as 
Acting Provost.  Secretary Heyman also instituted a different 
decision-making system for promotions, delegating responsi-
bility for promotions of scholarly staff to the Directors but 
with oversight responsibility in the Provost.  Generally, the 
Provost could consider promotions only of persons recom-
mended for promotion by the Director of the Museum.  Dr. 
Crew, in turn, reorganized the Museum to shift its strategic 
priorities from an "academic mode" toward a "customer ser-
vice" mode that would be more responsive to the public.  The 
curatorial units were reduced from twenty to five to ensure 
that curators would be better aware of the interrelationship 
between their field of expertise and others' and share their 
knowledge and research with the larger public.

     In April 1995, the peer evaluation committee recommended, 
for a third time, to the Museum Director that Dr. Forman be 
promoted to Grade 14.  Dr. Crew, however, advised Dr. 
Forman that he was going to postpone his final decision until 
he could review the results of Dr. Forman's performance plan 
for 1995-96.  While acknowledging the importance of scholar-
ship, Dr. Crew stated that "other factors also weigh quite 
heavily," most notably the relationship of one's work to the 
"strategic priorities of the museum" and "the priorities of 
[one's] supervisor."  Dr. Forman had expressed strong oppo-
sition to the new strategic priorities, and Dr. Crew explained 
that he wanted to determine whether Dr. Forman's perfor-
mance was consistent with the new priorities of the Museum 
and Forman's supervisors.  Dr. Crew did not forward the 
promotion package to the Acting Provost.

     Dr. Forman submitted a complaint to Acting Provost Hoff-
man, claiming that Hoffman had the authority to promote him 
unilaterally to Grade 14.  In a letter dated October 6, 1995, 
Secretary Heyman stated that he had requested that Hoff-
man advise him as to how to act on Dr. Forman's complaint;  
the Secretary was responding to a letter expressing concern 
about Dr. Forman's "long overdue promotion" and the impor-
tance to the Smithsonian of indicating that it "prize[s] schol-
arship, originality, and independence" as demonstrated by Dr. 
Forman.  Hoffman turned the complaint and accompanying 
materials over to Assistant Acting Provost Freudenheim for a 
recommendation; Freudenheim responded with a memoran-
dum, dated October 27, 1995, which Hoffman interpreted as 
implicitly recommending Dr. Forman's promotion.  In the 
absence of a recommendation from the Museum Director, 
however, Hoffman decided to ask Dr. Crew to reconsider his 
decision not to recommend Dr. Forman's promotion;  Dr. 
Crew did not respond.  Although Hoffman again favored Dr. 
Forman's promotion in light of his research accomplishments, 
he never "tested the system to determine" if he had "direct 
authority to overrule the museum director's recommenda-
tion," and he did not forward Dr. Forman's complaint to the 
Secretary, notwithstanding the Secretary's statement in Octo-
ber 1995 that "[Hoffman] expects to talk with all parties and 

then offer me guidance on how to proceed" regarding Dr. 
Forman's 1995 promotion.  Hoffman explained that he did 
not forward the complaint because Dr. Forman had already 
filed an EEO complaint, in which a decision would be made 
concerning the legitimacy of his claim.

     After exhausting his administrative remedies, see 29 C.F.R. 
s 1614.201(c), Dr. Forman filed a lawsuit against the Smith-
sonian under the ADEA, 29 U.S.C. s 633a, for age discrimi-
nation and retaliation.  The district court, observing that "[i]t 
may very well be that [Dr. Forman] ha[d] not been treated 
fairly by the Smithsonian," granted summary judgment to the 
Smithsonian on Dr. Forman's age discrimination and retalia-
tion claims.  The district court found that Dr. Forman had 
failed to show that age was a factor in the Smithsonian's 
refusal to promote him in 1991-92.  In so concluding, the 
district court found that the Smithsonian had articulated a 
legitimate nondiscriminatory reason for its decision not to 
promote him in 1991-92, namely his failure to produce a book 
or major publishable work as outlined in his performance 
plans, and that Dr. Forman had failed to show that this 
explanation was pretext for age discrimination.  The district 
court made similar findings as to the 1995 promotion, refer-
encing Dr. Crew's memorandum explaining why he was post-
poning Dr. Forman's promotion.  The court found that Dr. 
Forman failed to show that Dr. Crew's stated explanation for 
postponing promotion, namely that Dr. Forman was not 
meeting the expectations of his supervisors or aligning with 
the priorities of the Museum, was a pretext for retaliation, 
and presumably age discrimination.  The court also found no 
evidence of discriminatory retaliation by Dr. Crew or Acting 
Provost Hoffman when he failed to forward Dr. Forman's 
complaint to the Secretary.  In Part II we address Dr. 
Forman's promotion claims.  In Part III we address his 
retaliation claims.

                               II.

     On appeal, Dr. Forman contends that he presented a prima 
facie case of age discrimination because he was over forty 
years old when his promotions were denied, he was extraordi-
narily accomplished in his field, the peer committee recom-

mended him in relation to both promotions, he presented 
statistical evidence that reflected preferential treatment of 
younger curators, and, as to his 1991 promotion, age-laden 
comments strongly suggested age bias.  He also contends 
that he established a prima facie case of retaliation as to his 
1995 promotion because he engaged in protected activity by 
filing an EEO complaint regarding the denial of his 1991 
promotion, his supervisors knew of his EEO activity, and both 
Assistant Provost Freudenheim's memorandum and Acting 
Provost Hoffman's statement that he did not bring Dr. For-
man's promotion to the Secretary for decision because For-
man had filed an EEO challenge, constituted direct causal 
evidence between his protected activity and the denial of his 
promotion.  Dr. Forman further contends that he presented 
sufficient evidence to discredit the Smithsonian's reasons for 
rejecting both of his promotions.

     Our review of the grant of summary judgment is de novo.  
See Tao v. Freeh, 27 F.3d 635, 638 (D.C. Cir. 1994).  Accord-
ingly, the court must view the record in the light most 
favorable to the nonmoving party, according that party the 
benefit of all reasonable inferences.  See Anderson v. Liberty 
Lobby, Inc., 477 U.S. 242, 255 (1986);  see also Reeves v. 
Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000).  
Consistent with the courts' reluctance to become involved in 
the micromanagement of everyday employment decisions, see 
Brown v. Brody, 199 F.3d 446, 451-52 (D.C. Cir. 1999) (citing 
Mungin v. Katten, Muchin & Zavis, 116 F.3d 1549, 1556-57 
(D.C. Cir. 1997));  Fishbach v. D.C. Dep't of Corr., 86 F.3d 
1180, 1183 (D.C. Cir. 1996), the question before the court is 
limited to whether Dr. Forman produced sufficient evidence 
of age discrimination, not whether he was treated fairly or 
otherwise entitled to promotion.  The Smithsonian does not 
dispute that Dr. Forman is highly praised by outside scholars 
for both his exhibits and scholarly writing and that he was 
generally qualified for promotion.

     Section 633a of the ADEA provides that "All personnel 
actions affecting employees ... in the Smithsonian Institution 
... who are at least 40 years of age ... shall be made free 
from any discrimination based on age."  29 U.S.C. s 633a(a) 

(Supp. V 1999).  This circuit applies to ADEA cases the 
scheme for allocating evidentiary burdens that has evolved in 
Title VII discrimination cases.  See Krodel v. Young, 748 
F.2d 701, 705 (D.C. Cir. 1984).  Thus, as summarized in 
Cuddy v. Carmen, 762 F.2d 119 (D.C. Cir. 1985), the plaintiff 
must first establish a prima facie case of discrimination.  Id. 
at 122.  Upon so doing, the burden of production shifts to the 
employer to offer a legitimate nondiscriminatory reason for 
its action.  Id.  Upon the employer's meeting of this burden 
of production, the plaintiff, however, carries the overall bur-
den of persuasion, which may be met either indirectly by 
showing the employer's reason is pretextual or directly by 
showing that it was more likely than not that the employer 
was motivated by discrimination.  Id. at 123;  see Reeves, 530 
U.S. at 143, 146-47.

     The ultimate question is whether age was a determining 
factor in the disputed employment decision.  See Cuddy, 762 
F.2d at 123.  In failure to promote cases, a prima facie case is 
made by showing:  (1) the plaintiff is at least forty years of 
age;  (2) the plaintiff was qualified for the position in question;  
(3) the plaintiff was not promoted;  and (4) the plaintiff was 
disadvantaged in favor of a younger person.  See Cuddy v. 
Carmen, 694 F.2d 853, 856-57 (D.C. Cir. 1982).

                                A.

     Regarding the denial of his 1991 promotion, Dr. Forman 
presented evidence that he was a member of the protected 
class, he was generally qualified for promotion to Grade 14, 
and yet he was not promoted.  He also presented evidence 
that he alone of all curators had been twice denied pro-
motions in the face of two recommendations by the peer 
committee.  To support the fourth element of his prima facie 
case, Dr. Forman presented expert statistical evidence to 
show that younger employees were favored for promotion.  
Specifically, Dr. Forman presented evidence that persons 
under forty-five years of age had a higher rate of promotion 
to Grade 14 than those over forty-five, and that there was an 

inverse correlation between a curator's age and the annual 
ratings given for research.  These differences were statisti-
cally significant using either a one-tailed or two-tailed test of 
significance.  See Palmer v. Shultz, 815 F.2d 84, 90-97 (D.C. 
Cir. 1987).  This circuit recognizes statistical data as relevant 
in individual discrimination claims.  See Minority Employees 
at NASA v. Beggs, 723 F.2d 958, 962 (D.C. Cir. 1983);  see 
also Bell v. EPA, 232 F.3d 546, 553 (7th Cir. 2000);  Adams v. 
Ameritech Servs., Inc., 231 F.3d 414, 423-24, 427 (7th Cir. 
2000).  Although the Smithsonian showed that several older 
curators were promoted, this is not dispositive, see O'Connor 
v. Consol. Coin Caterers Corp., 517 U.S. 308, 312 (1996), and 
Dr. Forman maintains that the Smithsonian never disputed 
the overall statistical trend.  The Smithsonian maintains that 
the statistics are deficient because they rely on an overly 
broad data pool, but the Smithsonian does not dispute that 
the statistics were based on information that it supplied in 
response to Dr. Forman's discovery requests.

     In any event, Dr. Forman introduced other evidence that 
age was a primary consideration in the denial of his pro-
motion in 1991 to meet his prima facie burden, which is not 
onerous.  See Tex. Dep't of Cmty. Affairs v. Burdine, 450 
U.S. 248, 253 (1981).  Dr. Forman presented evidence that 
when Secretary Adams was reviewing Dr. Forman's 1991 
promotion papers with the two Assistant Secretaries, a series 
of comments were made that implicitly referred to Dr. For-
man's age.  According to Assistant Secretary Hoffman, com-
ments were made that Dr. Forman may be "over the hill" or 
in the "twilight of his career," and may have "written his last 
significant article."  As pointed out in Hunt v. City of Mark-
ham, 219 F.3d 649 (7th Cir. 2000), when decision makers, or 
those who have input into the decision, express such discrimi-
natory feelings around the relevant time in regard to the 
adverse employment action complained of, "then it may be 
possible to infer that the decision makers were influenced by 
those feelings in making their decisions."  Id. at 653.  More-
over, the employer's correlation of old age with declining 
productivity represents the very essence of age discrimina-
tion.  See Hazen Paper Co. v. Biggins, 507 U.S. 604, 610 

(1993);  cf. Price Waterhouse v. Hopkins, 490 U.S. 228, 251 
(1989).

     With this evidence, Dr. Forman has presented a prima 
facie case that shifts the burden of coming forward with 
evidence to the Smithsonian to show that its action was not 
based on Dr. Forman's age.  The Smithsonian has met this 
burden of production, presenting evidence that Dr. Forman 
was not promoted because of his failure to produce a book-
length manuscript on atomic clocks "or any other work of 
comparable scope."  Because Dr. Forman has no direct evi-
dence of age discrimination, the dispositive question is wheth-
er he showed that the Smithsonian's explanation for its 
decision not to promote him in 1991 was a pretext for 
discrimination.  See St. Mary's Honor Ctr. v. Hicks, 509 U.S. 
502, 511 (1993).  Dr. Forman disputes that he was obligated 
to produce a book during his New York City sabbatical, and 
maintains that he, in fact, produced the quantitative word 
target set for his sabbatical and was productively focusing on 
Townes (but could not complete the biography because 
Townes was refusing access to his papers).  Dr. Forman 
questions why completion of yet another major scholarly 
work was made a condition of his promotion, observing that 
this supposedly critical requirement vanished in later years 
and that completion of a book was not generally a require-
ment for promotion.  This is insufficient evidence to show 
pretext.

     It is undisputed that Dr. Forman's performance plans for 
the relevant period called for him to produce a book or 
comparable body of work.  Dr. Forman did not produce 
evidence to show fulfillment of this requirement.  The fact 
that completion of a book dropped from later promotion 
decisions is insufficient to show pretext because the later 
promotion decisions occurred under different decision makers 
using different procedures, having different priorities, and 
considering different performance evaluations.  Further, the 
fact that Dr. Forman may have met word targets is not the 
equivalent of producing a final book-length manuscript;  the 
latter, not merely the former, was specified in his perfor-
mance plans, and Dr. Forman admitted that he finished 

neither his atomic clock book nor his Townes manuscript.  
Nor does Dr. Forman's inability to finish his Townes manu-
script because of factors beyond his control rebut the fact 
that he did not produce a critical element of his performance 
plan for several years.  Hence, notwithstanding the age-
based comments at the discussion of his promotion, the 
Smithsonian produced evidence of a nondiscriminatory reason 
for denying him a noncompetitive promotion in 1991.

     Dr. Forman's reliance on Aka v. Washington Hospital 
Center, 156 F.3d 1284 (D.C. Cir. 1998), is appropriate to the 
extent it sets forth the proper legal analysis, but Aka high-
lights precisely what is missing here.  In Aka, the plaintiff 
offered evidence from which a reasonable jury could find that 
he was "markedly more qualified" than the person selected 
for the position at issue.  Id. at 1299.  Dr. Forman's task is 
more difficult to the extent he is competing against himself.  
That the promotion of others did not depend on completion of 
a book is irrelevant to Dr. Forman's particular promotion 
decision.  Unless he could show that he had fulfilled the 
central purpose of his sabbatical and performance plans, he 
cannot show that Secretary Adams' reason for denying his 
promotion was pretextual.  As the district court explained to 
Dr. Forman:

     What is relevant is that they thought your work product 
     or your output was inadequate, given the fact that you 
     had no other significant responsibilities during that peri-
     od of time, and that you were expected, during that two-
     year period of time, to produce publishable-quality writ-
     ten material. * * *  You may disagree with their evalua-
     tion of what you were doing that period of time, but 
     that's not age discrimination.
     
                                B.

     Dr. Forman's 1995 promotion age-discrimination claim is 
supported by neither the statistical evidence nor the age-
based remarks by decision makers that he presented in 
connection with the denial of his 1991 promotion.  The statis-
tical evidence, which examined only 1990 to 1993 and 1987 to 

1992, does not address the relevant period, and there is no 
evidence to support the inference that the statistical trends 
during these periods extended to 1995.  As to Dr. Forman's 
age, Dr. Crew, the Director who made the decision to post-
pone his decision on Dr. Forman's promotion until his perfor-
mance during the upcoming year could be evaluated, stated 
that he was unaware of Dr. Forman's age when he decided to 
postpone Forman's promotion.  Although Dr. Forman main-
tains this denial is evidence of age discrimination, this is 
speculation, which is not the same as evidence showing that 
age was a substantial factor in Dr. Crew's decision.  See 
McGill v. Munoz, 203 F.3d 843, 846 (D.C. Cir. 2000);  see also 
Fed. R. Civ. P. 56(e).  Rather, the evidence showed that Dr. 
Crew focused on whether Dr. Forman would adapt to the 
Museum's new direction and his supervisor's expectations.  
Other evidence corroborates Dr. Crew's explanation.  Dr. 
Forman had protested the Museum's new direction, thereby 
indicating that the Museum did have a new focus.  Further, 
Dr. Forman's immediate supervisor had raised some of the 
same concerns expressed by Dr. Crew, urging Dr. Forman to 
collaborate more with others and do some new exhibition 
work and thus "expand the audiences with whom he is 
communicating."  The evidence that Dr. Forman produced to 
suggest that Assistant Acting Provost Freudenheim ques-
tioned whether the Museum had such a new direction was 
later retracted by Freudenheim as being based on only 
information provided by Dr. Forman, and in any event, at 
most, suggests that Dr. Crew's stated explanation might be 
false, not that Dr. Crew's decision was age-based.

     For these reasons, we hold that Dr. Forman failed to 
present a prima facie case of age discrimination in the 1995 
denial of his promotion.

                               III.

     We conclude, however, that Dr. Forman produced sufficient 
evidence to establish a prima facie case of retaliation when 
Acting Provost Hoffman failed to forward Dr. Forman's 
complaint materials in response to Secretary Heyman's re-

quest for advice on Dr. Forman's 1995 promotion.  In con-
trast, Dr. Forman did not present a prima facie case of 
retaliation as a result of Dr. Crew's failure to promote him.  
We first address a threshold jurisdictional issue, however, 
before turning to the merits.

                                A.

     For purposes of the ADEA, the Smithsonian is included in 
the section addressing age discrimination in federal agency 
employment.  See 29 U.S.C. s 633a(a) (Supp. V 1999).  Al-
though the court has considered whether the Smithsonian is a 
federal agency under certain statutes, see Expeditions Un-
limited Aquatic Enters. v. Smithsonian Inst., 566 F.2d 289, 
296 (D.C. Cir. 1977);  Dong v. Smithsonian Inst., 125 F.3d 
877, 879 (D.C. Cir. 1997), it has yet to address whether the 
Smithsonian is entitled to sovereign immunity.

     Several elements of the Smithsonian's congressional design 
would appear to suggest that it does have sovereign immuni-
ty.  First, it operates under a federal charter, 20 U.S.C. s 41, 
and its Board of Regents is composed of or selected by 
federal officials, id. ss 42-43.  Second, it is authorized to 
receive appropriations from Congress.  See id. ss 53a, 54;  
General Hearings Before the Subcommittee on Library and 
Memorials, 91st Cong. 323 (1970), cited in Expeditions Un-
limited Aquatic Enters., 566 F.2d at 296 n.4.  Third, "[a]ll 
moneys recovered by or accruing to, the institution shall be 
paid into the Treasury of the United States, to the credit of 
the Smithsonian bequest, and separately accounted for," 20 
U.S.C. s 53, and disbursements for payments of debt are 
submitted to the Treasury, id. s 57.  Ultimately, as the 
Supreme Court observed in Land v. Dollar, 330 U.S. 731 
(1947), whether "a suit is one against the sovereign" turns on 
whether "[t]he 'essential nature and effect of the proceeding' 
may be such as to make plain that the judgment sought would 
expend itself on the public treasury or domain, or interfere 
with the public administration."  Id. at 738 (quoting Ex parte 
State of New York, 256 U.S. 490, 500, 502 (1921)).  Thus, 
notwithstanding that the Smithsonian is authorized to receive 

gifts from private sources, see 20 U.S.C. s 55, the Smithsoni-
an's structure and federal funding would suggest that Con-
gress's interest in safeguarding the public fisc from money 
judgments is no less significant with respect to the Smithsoni-
an than any federal agency.  Cf. Story v. Snyder, 184 F.2d 
454, 457 (D.C. Cir. 1950).  Nonetheless, we do not decide the 
issue.  Rather, in order to ensure a consistent reading of the 
scope of s 633a, we assume that the Smithsonian has sover-
eign immunity.

     Consequently, before addressing the merits of Dr. For-
man's retaliation claims, we must first determine whether Dr. 
Forman, as an employee of the Smithsonian, may bring a 
retaliation claim under s 633a of the ADEA.  Although the 
Smithsonian, which is represented by the United States At-
torney, does not question whether s 633a prohibits retalia-
tion, the court must because "officers of the United States 
possess no power through their actions to waive an immunity 
of the United States or to confer jurisdiction on a court in the 
absence of some express provision of Congress."  Dep't of the 
Navy v. Fed. Labor Relations Auth., 56 F.3d 273, 275 (D.C. 
Cir. 1995) (quoting United States v. N.Y. Rayon Importing 
Co., 329 U.S. 654, 660 (1947));  see also First Va. Bank v. 
Randolph, 110 F.3d 75, 77 (D.C. Cir. 1997).

     "In analyzing whether Congress has waived the immunity 
of the United States, we must construe waivers strictly in 
favor of the sovereign and not enlarge the waiver beyond 
what the language requires."  Library of Congress v. Shaw, 
478 U.S. 310, 318 (1986) (citations omitted) (internal quotation 
marks omitted);  accord United States v. Nordic Village, Inc., 
503 U.S. 30, 34 (1992).  Thus, waiver cannot be implied;  it 
must be unequivocally expressed.  United States v. Mitchell, 
445 U.S. 535, 538 (1980);  Dorsey v. U.S. Dep't of Labor, 41 
F.3d 1551, 1554-55 (D.C. Cir. 1994).  Accordingly, we turn to 
the text of s 633a.

     Congress expanded the scope of the ADEA in 1974 to 
include state and local governments and federal employers.  
See Pub. L. No. 93-259, 88 Stat. 74 (1974) (codified as 
amended at 29 U.S.C. ss 630(b), 633a).  Unlike state and 

local governments, which were merely added to the definition 
of "employer" in the ADEA, Congress created an entirely 
new section of the ADEA in which it waived federal sovereign 
immunity.  This section, codified as s 633a, provides that 
"[a]ll personnel actions affecting [federal agency] employees 
... shall be made free from any discrimination based on age."  
29 U.S.C. s 633a(a).  Thus, "Congress deliberately prescribed 
a distinct statutory scheme applicable only to the federal 
sector."  Lehman v. Nakshian, 453 U.S. 156, 167 n.15 (1981).  
Unlike s 623(d), the ADEA provision governing private, 
state, and local employers, however, s 633a does not by its 
terms expressly prohibit retaliation.  Section 623(d) explicitly 
includes retaliation within the specified prohibited forms of 
discrimination under the ADEA, providing that "[i]t shall be 
unlawful for an employer to discriminate against any of his 
employees ... because such individual ... has made a 
charge, ... or participated in any manner in an investigation, 
proceeding, or litigation under [the ADEA]."  29 U.S.C. 
s 623(d) (1994).  Moreover, the prohibition of retaliation con-
tained in s 623(d) does not apply to federal employees not 
only because the ADEA defines "employer" as used in 
s 623(d) to exclude the federal government, see 29 U.S.C. 
s 630(b), but also because s 633a(f) specifically provides that 
s 633a should not be subject to the provisions of s 623.

     These statutory differences between the federal and private 
sectors are not dispositive, however, as some courts have 
concluded in holding that s 633a does not allow a claim for 
retaliation, see Tomasello v. Rubin, 920 F. Supp. 4, 5-6 
(D.D.C. 1996), aff'd on other grounds, 167 F.3d 612 (D.C. Cir. 
1999);  Koslow v. Hundt, 919 F. Supp. 18, 19-21, 21 (D.D.C. 
1995), for it is the language that Congress used in s 633a(a) 
alone that determines the scope of that provision.  Unlike 
s 623, which is narrowly drawn and sets forth specific prohib-
ited forms of age discrimination in private employment, Con-
gress used sweeping language when it subsequently extended 
the ADEA to cover federal agency employees.  Congress 
required no less than that "[a]ll personnel actions affecting 
employees ... who are at least 40 years of age ... shall be 
made free from any discrimination based on age."  29 U.S.C. 

s 633a(a) (emphasis added).  In enacting s 633a(a), Congress 
used unqualified language that encompasses a claim of retali-
ation because "analytically a reprisal for an age discrimina-
tion charge is an action in which age bias is a substantial 
factor."  See Siegel v. Kreps, 654 F.2d 773, 782 n.43 (D.C. Cir. 
1981) (Robinson, J., concurring in part and dissenting in part) 
(citations omitted).  Congress's failure to mention "retalia-
tion" explicitly does not undermine its intended breadth of 
the provision.  Cf. PGA Tour, Inc. v. Martin, 121 S. Ct. 1879, 
1897, (2001);  Teva Pharm., USA, Inc. v. U.S. Food & Drug 
Admin., 182 F.3d 1003, 1011 (D.C. Cir. 1999).  It is difficult to 
imagine how a workplace could be "free from any discrimina-
tion based on age" if, in response to an age discrimination 
claim, a federal employer could fire or take other action that 
was adverse to an employee.  To treat Congress's mandate as 
other than comprehensive would produce absurd results, 
which courts are to avoid.  See Griffin v Oceanic Contractors, 
Inc., 458 U.S. 564, 575 (1982).  Nothing in the plain language 
of s 633a suggests that Congress intended the federal work-
place to be less free of age discrimination than the private 
workplace.  To the contrary, Congress's actions show that it 
intended its mandate to reach more broadly in the federal 
sector than in the private sector.  In amending the ADEA in 
1978, Congress eliminated the upper age limit for federal 
employees in order to effectively end mandatory retirement 
in the federal sector in most instances, whereas it merely 
increased the coverage from 65 to 70 for private employers, 
limiting the protection from mandatory retirement in the 
private sector.  See H.R. Rep. No. 95-950, at 2, 7-8, 10-11 
(1978) (Conference Report);  124 Cong. Rec. 8,218 (1978) (Sen. 
Javits, ranking minority member of the Human Resources 
Committee).  Moreover, the intent of Congress as expressed 
in the legislative history of s 633a(a) was to "remove discrimi-
natory barriers against employment of older workers in gov-
ernment jobs at the Federal and local government levels as 
[the ADEA] has and continues to do in private employment."  
S. Rep. No. 93-690, at 56 (1974);  see also 120 Cong. Rec. 
8,768 (1974) (remarks of Sen. Bentsen, principal proponent of 
ADEA extension to federal employees).

     This focus on the sweeping language used by Congress is 
the same reasoning that the court relied upon in holding that 
s 2000e-16, in which Congress waived sovereign immunity 
for claims under Title VII, includes a claim for retaliation.  
See Ethnic Employees of the Library of Congress v. Boorstin, 
751 F.2d 1405, 1415 & n.13 (D.C. Cir. 1985) (citing Porter v. 
Adams, 639 F.2d 273, 277-78 (5th Cir. 1981)).  In Porter, the 
Fifth Circuit explained that s 2000e-16 differs from 
ss 2000e-3 and 2000e-4, which are narrowly drawn and 
prohibit only specific forms of discrimination, because 
s 2000e-16 is drafted broadly to prohibit "any discrimination 
based on race, color, religion, sex, or national origin."  42 
U.S.C. s 2000e-16;  see Porter, 639 F.2d at 277-78.  The 
court reasoned that "the reasonable conclusion, therefore, is 
that by drafting [s 2000e-16] to prohibit 'any discrimination,' 
Congress intended to bar the federal government from en-
gaging in all those forms of discrimination identified in 
[ss 2000e-3 and 2000e-4], and others as well."  Porter, 639 
F.2d at 278;  see also White v. Gen. Servs. Admin., 652 F.2d 
913, 917 (9th Cir. 1981).  Sections 633a and 2000e-16 use 
identical language in creating a cause of action for federal 
employees under the ADEA and Title VII, respectively, and 
thus should be interpreted consistently.  Indeed, the Su-
preme Court has noted that s 633a, as finally enacted, is 
"patterned directly after [s 2000e-16] of the Civil Rights Act 
of 1964, which extend Title VII protections to federal employ-
ees."  Lehman, 453 U.S. at 167 n.15.  Notably, the statutory 
pattern here favors an unqualified interpretation of Congres-
sional intent, unlike the statutory pattern that confronted the 
Court in Lehman.  See id. at 161.

     The fact that, unlike s 2000e-16 of Title VII, s 633a of the 
ADEA contains an exclusivity provision does not defeat our 
analysis.  The exclusivity provision provides that federal per-
sonnel actions under s 633a "shall not be subject to, or 
affected by, any provision of this chapter," with one exception 
not relevant here, see 29 U.S.C. s 633a(f), and makes s 633a 
"self-contained and unaffected by other sections."  Lehman, 
453 U.S. at 168.  Courts relying on s 633a(f) in concluding 
that s 633a does not allow a claim of retaliation, see Tomasel-

lo, 920 F. Supp. at 6;  Koslow, 919 F. Supp. at 19-20, point to 
the Supreme Court's language in Lehman that s 633a(f) 
means that "federal personnel actions covered by [s 633a] are 
not subject to any other section of the ADEA," Lehman, 453 
U.S. at 168, and reason that "Congress has made clear that in 
interpreting section 633a, the Court may not borrow provi-
sions from elsewhere in the ADEA."  Koslow, 919 F. Supp. at 
19-20;  Tomasello, 920 F. Supp. at 6.  The reasoning fails for 
two reasons.

     First, nothing in the legislative history of s 633a(f), which 
was added to s 633a in 1978, see Pub. L. No. 95-256, 92 Stat. 
191 (1978), suggests that it was intended to limit the broad 
coverage of s 633a that was originally intended.  As noted, 
the 1978 amendments imposed more stringent requirements 
upon the federal sector than the private sector.

     Second, our analysis is consistent both with s 633a(f) and 
Lehman's interpretation of it because we do not borrow 
provisions from elsewhere in the ADEA;  rather, we rely on 
Congress's use of sweeping language in s 633a(a) itself to 
make unlawful "any discrimination" based on age, as age is 
defined in the ADEA.  In Lehman, the Supreme Court 
considered whether a federal employee bringing suit pursuant 
to s 633a had a right to a jury trial.  Id. at 157.  The Court 
did not hold, as Koslow implies, that s 633a(f) precludes 
courts from interpreting s 633a(a) as prohibiting the same 
conduct prohibited in the private sector in other provisions of 
the ADEA;  rather, Lehman began its analysis with the plain 
language of s 633a, asking first whether it contained an 
express provision of a jury trial.  Working against the back-
ground principle that "[w]hen Congress has waived the sover-
eign immunity of the United States, it has almost always 
conditioned that waiver upon a plaintiff's relinquishing any 
claim to a jury trial," id. at 161, the Court found no Congres-
sional intent to provide federal employees a jury trial because 
there was no express provision for a jury trial in s 633a, 
whereas Congress had expressly provided for one for private 
employees.  Id. at 163.  In further support of its conclusion, 
the Court pointed to s 633a(f), noting that, in light of Con-
gress's emphasis that s 633a was self-contained, Congress 

would not have overlooked the need to provide federal em-
ployees a jury trial if it had so intended.  Id. at 168.

     In the end, then, s 633a(f) presents somewhat of a red 
herring.  We do not incorporate the provisions of s 623(d) 
into s 633a in concluding that s 633a supports a retaliation 
claim against the federal government.  Compare Ayon v. 
Sampson, 547 F.2d 446, 449-50 (9th Cir. 1976).  To the 
contrary, we are relying on the plain language of s 633a(a) in 
holding that a work place cannot be free from any age 
discrimination if an employer can take an adverse employ-
ment action against its employees because the employee has 
brought an age discrimination claim against the employer.  
This is age discrimination, which s 633a(a) by its own terms 
alone prohibits.

     For these reasons, we hold that s 633a waives sovereign 
immunity as to claims of retaliation.  We proceed, therefore, 
to address the merits of Dr. Forman's claims.

                                B.

     The McDonnell Douglas framework is applicable to claims 
of retaliation.  See Passer v. Am. Chem. Soc'y, 935 F.2d 322, 
330 (D.C. Cir. 1991);  cf. McKenna v. Weinberger, 729 F.2d 
783, 790 (D.C. Cir. 1984).  In order to establish a prima facie 
case of retaliation, a plaintiff must show that (1) he engaged 
in protected activity, (2) he was qualified for the promotion, 
(3) the employer took an adverse personnel action, and (4) a 
causal connection existed between the protected activity and 
the adverse action.  See Paquin v. Fed. Nat'l Mortgage 
Ass'n, 119 F.3d 23, 31 (D.C. Cir. 1997);  Mitchell v. Baldrige, 
759 F.2d 80, 86 n.5 (D.C. Cir. 1985);  McKenna, 729 F.2d at 
790.  The initial burden is not great, as the plaintiff need only 
establish facts adequate to permit an inference of retaliatory 
motive.  See McKenna, 729 F.2d at 790.

     The district court was unpersuaded that Dr. Forman had 
made a prima facie case of retaliation.  The court construed 
Hoffman's statement that he did not bring Dr. Forman's 
complaint to the Secretary "since Dr. Forman had already 
filed an EEO complaint, in the course of which a decision 

would be reached concerning the legitimacy of his claim" to 
be, "Let's leave it to the courts."  Recognizing that Hoffman 
had previously supported Dr. Forman's promotion, the court 
rejected Dr. Forman's argument that Hoffman's statement 
was per se reprisal and that as a result of Hoffman's inaction, 
Dr. Forman was deprived of consideration and procedures 
from which he otherwise would have benefitted.  The district 
court erred by not viewing the evidence most favorably to 
Forman in granting summary judgment.  Dr. Forman met 
his burden by presenting direct evidence of retaliatory mo-
tive.  Despite Secretary Heyman's request for advice about 
how to proceed on Dr. Forman's 1995 promotion, Acting 
Provost Hoffman never forwarded Dr. Forman's complaint 
materials to the Secretary because, according to Hoffman 
himself, Dr. Forman had filed an EEO complaint about his 
1991 promotion.  Hoffman's explanation for not doing so was 
that the EEO proceeding would determine whether Dr. For-
man was entitled to his promotion.  While these and other 
evidentiary issues will remain open on remand, for purposes 
of summary judgment, Dr. Forman is entitled to the benefit 
of all reasonable inferences from the evidence before the 
district court.

     It is true that Hoffman supported Dr. Forman's promotion.  
And it may be true that his failure to forward the complaint 
to the Secretary was in good faith.  But motive, in the sense 
of malice is not required for liability under the ADEA.  
Malicious or reckless motive is only pertinent to the issue of 
liquidated or double damages, which Congress intended to be 
punitive in nature and are not relevant here.  See 29 U.S.C. 
s 626(b);  id. s 216(b);  Trans World Airlines, Inc. v. Thur-
ston, 469 U.S. 111, 125 (1985);  Smith v. Office of Personnel 
Mgmt., 778 F.2d 258, 261 (5th Cir. 1985);  see also 42 U.S. C. 
l981a(b)(1).  "[A]n employer may offer a legitimate non-
discriminatory reason for taking an adverse action against an 
employee who has engaged in protected activity....  Howev-
er, the employer may not proffer a good faith reason for 
taking retaliatory action."  EEOC v. Bd. of Governors of 
State Colls. & Univs., 957 F.2d 424, 427-28 (7th Cir. 1992);  
see also Hazen Paper, 507 U.S. at 616;  Trans World Air-

lines, 469 U.S. at 126 & n.19.  Unlawful motive, not malicious 
motive, is all that Dr. Forman had to show.

     Consequently, even if Hoffman acted in good faith in failing 
to forward Dr. Forman's complaint to the Secretary, he 
nonetheless would violate the ADEA if his reason for doing so 
was retaliatory, i.e., in response to Dr. Forman's 1991 EEO 
complaint.  Dr. Forman offered evidence, sufficient to defeat 
summary judgment, of such a retaliatory and hence unlawful 
motive through Hoffman's own explanation of his inaction.  
Hoffman's statement is direct evidence that his failure to take 
Dr. Forman's complaint to the Secretary was substantially 
motivated by Dr. Forman's prior EEO complaint and hence 
was retaliatory.  Moreover, giving Dr. Forman the benefit of 
all reasonable inferences, it is unclear whether Hoffman could 
reasonably have thought that the pending EEO proceeding 
involving Dr. Forman's 1991 promotion, which turned on his 
failure to produce a book or book-length manuscript, would 
resolve Dr. Forman's complaint about the denial of his 1995 
promotion, which turned on other factors, such as concern 
whether he would adapt to the Museum's new focus.  Al-
though Hoffman may have thought that administrative reso-
lution of the 1991 promotion in Dr. Forman's favor would 
have resolved the question of promotion in 1995, an adverse 
resolution would have left unresolved Dr. Forman's claim of 
discrimination in 1995.  Without a connection between the 
two, Hoffman's conduct could reasonably be interpreted as 
involving more than "leaving it to the courts."

     Dr. Forman also provided evidence of the remaining ele-
ments of a prima facie case of retaliation.  First, Dr. For-
man's filing of an administrative complaint regarding the 
denial of his 1991 promotion, as well as his appeal to the 
Equal Employment Opportunity Commission, were protected 
activities.  See 29 U.S.C. s 623;  Holbrook v. Reno, 196 F.3d 
255, 263 (D.C. Cir. 1999).  Second, he was generally qualified 
for the promotion, and the Smithsonian does not dispute this.  
Third, Hoffman's failure to take Dr. Forman's complaint to 
the Secretary constituted an adverse employment action, 
viewing the record most favorably to Dr. Forman.  The 
record before the district court showed that Secretary Hey-

man had delegated promotion responsibility to the Directors, 
but Dr. Forman introduced evidence that the Secretary had 
made an exception in Dr. Forman's case, expressly stating 
that Hoffman was to advise him on Dr. Forman's promotion.  
Also, the Secretary retained the authority to unilaterally 
promote curators.  Notwithstanding the Secretary's request, 
Hoffman, although aware of the Secretary's statement that he 
was awaiting Hoffman's recommendation, never advised the 
Secretary how to proceed on Dr. Forman's promotion.  Hoff-
man's reason for not acting was that Dr. Forman had filed an 
EEO complaint.  As a result of Hoffman's inaction, a reason-
able fact finder could find that Dr. Forman was denied the 
opportunity for promotion that the Secretary had afforded 
him.  The Smithsonian did not contend that Dr. Forman 
would not have been promoted had Hoffman taken Dr. For-
man's complaint to the Secretary for action.  Thus, Dr. 
Forman's evidence that Hoffman's inaction was an adverse 
employment action is sufficient to defeat summary judgment 
for failure to establish a prima facie case of retaliation.  See 
Cones v. Shalala, 199 F.3d 512, 521 (D.C. Cir. 2000);  see also 
Ruggles v. Cal. Polytechnic State Univ., 797 F.2d 782, 785-86 
(9th Cir. 1986).  Further, the Smithsonian's characterization 
of its action as a postponement rather than a denial is to no 
avail;  for purposes of summary judgment, Hoffman's inaction 
was the equivalent of non-promotion.  See Price Waterhouse, 
490 U.S. at 233 n.1.

     Dr. Forman's claim that Dr. Crew retaliated against him as 
a result of his EEO complaint fails, however, because Dr. 
Forman does not allege sufficient facts to show causation.  
Although Dr. Crew knew of the EEO complaint, his decision 
not to promote Dr. Forman in 1995 occurred three years after 
Dr. Forman filed his EEO complaint, which challenged his 
non-promotion in 1991 under a different Smithsonian adminis-
tration, and after changes had been made in the Museum's 
curatorial staff.  Because of the time lapse, Dr. Forman 
cannot rely solely on the timing of Dr. Crew's decision not to 
promote him to show causation.  See Holbrook v. Reno, 196 
F.3d 255, 263 (D.C. Cir. 1999);  Mitchell v. Baldridge, 759 
F.2d 80, 86 (D.C. Cir. 1985).  Assistant Acting Provost Freu-

denheim's evaluation of Dr. Crew's denial of promotion also 
cannot support a causal connection between Dr. Crew's fail-
ure to promote Dr. Forman and Dr. Forman's protected 
activity.  After discussing the 1995 promotion decision with 
Dr. Forman, Freudenheim indicated that he thought that "it 
looks like [Dr. Forman] is being handled prejudicially (either 
because he previously sued, or because he's not part of some 
vague team concept), and I suspect that [the Smithsonian] 
will not win this one if it goes into formal legal processes."  
As noted, Freudenheim later qualified this statement, explain-
ing that it was based solely on information Dr. Forman had 
provided and that he did not have "all of the pertinent 
information at [his] disposal at the time [he] expressed [his] 
view."  Although Dr. Forman is entitled on summary judg-
ment to have Freudenheim's initial letter credited, see Reeves, 
530 U.S. at 150, it is insufficient to establish causation be-
cause it is not based on personal knowledge, but rather is 
mere speculation.  See McGill, 203 F.3d at 846;  see also Fed. 
R. Civ. P. 56(e).

     Accordingly, because Dr. Forman has established a prima 
facie case of retaliation, and the Smithsonian has failed to 
meet its burden of production to set forth a legitimate, non-
retaliatory reason for Hoffman's failure to act on Dr. For-
man's complaint, we reverse the grant of summary judgment 
on Forman's 1995 retaliation claim;  we otherwise affirm.  Dr. 
Forman's only other contention, that the district court abused 
its discretion in denying him further discovery is unpersua-
sive in view of the wide scope of discretion accorded to the 
district court.  See, e.g., United States v. Microsoft Corp., 253 
F.3d 34, 100-01 (D.C. Cir. 2001) (per curiam), cert. denied on 
other grounds, 70 U.S.L.W. 3107 (U.S. Oct. 9, 2001);  Carey 
Canada, Inc. v. Columbia Cas. Co., 940 F.2d 1548, 1559 (D.C. 
Cir. 1991).