## Facts

- Tia Robinson was hired as an account executive for W*USA-TV (a division of The Detroit News, Inc.) to generate new advertising sales and handle certain transactional advertising accounts.
- Before accepting the job, Robinson had experience in marketing and new business development but lacked transactional-account experience.
- Robinson alleged that the sales manager and vice president of sales promised she would receive training on transactional accounts; a coworker present at an interview corroborated that training was promised.
- Robinson left her prior position at another television station and joined W*USA in reliance on the promised training; her employment was expressly at will, with no term agreement.
- Robinson asserted that she received only limited training and that two later-hired male account executives received more extensive training and favorable treatment.
- After approximately six months, W*USA terminated Robinson, citing failure to generate new business and difficulty with math-related aspects of the work.
- Robinson sued for breach of contract, promissory estoppel, breach of the covenant of good faith, and sex discrimination under the D.C. Human Rights Act (DCHRA); the case proceeded in federal court after removal.

## Issues

1. Whether the at-will employment relationship and the parties’ conduct entitled the employer to summary judgment on breach of contract and breach of the covenant of good faith claims.
2. Whether Robinson presented sufficient evidence to create a triable promissory estoppel claim based on alleged preemployment promises of training and reliance damages.
3. Whether Robinson established a prima facie case of sex discrimination under the DCHRA, including by showing similarly situated male comparators treated more favorably.
4. Whether the court should permit a further amended complaint, and whether an unauthorized surreply should be stricken.

## Decision

- Summary judgment was granted to the employer on breach of contract and breach of the covenant of good faith.
- Summary judgment was denied on promissory estoppel because disputed facts existed about a clear training promise, reasonable reliance, and detriment.
- Summary judgment was granted to the employer on the DCHRA sex-discrimination claim for failure to establish a prima facie case.
- The plaintiff’s surreply was stricken as unauthorized and repetitive.
- The plaintiff’s motion to amend was denied as untimely and futile.

## Legal Principles

- In summary-judgment practice, when a party fails to address an argument directed at particular claims, the court may treat those points as conceded.
- At-will employment generally defeats claims that depend on proving a contractual right to continued employment or an implied covenant tied to such a contract.
- Promissory estoppel under D.C. law requires evidence of (1) a clear and definite promise, (2) expectation of reliance, (3) actual and reasonable reliance, and (4) resulting detriment; an at-will relationship does not bar an estoppel claim based on a separate, preemployment promise.
- Under the McDonnell Douglas framework as applied to the DCHRA, a plaintiff relying on comparator evidence must show that purported comparators are similarly situated in relevant respects; differences in job responsibilities or standards can defeat the prima facie showing.
- Surreplies are generally disallowed absent leave of court and are appropriate only to address new arguments raised in a reply.

## Conclusion

The court allowed Robinson’s promissory estoppel claim to proceed because a jury could find that specific prehire promises of transactional-account training induced her to leave prior employment to her detriment, while dismissing her contract, good-faith, and DCHRA discrimination claims and denying further pleading expansion and unauthorized briefing.


Robinson v. The Detroit News, Inc., 211 F. Supp. 2d 101 (D.D.C. 2002)