Laughlin v. Metropolitan Washington Airports Authority

After learning airport manager Augustus Melton had drafted but never sent a warning letter to supervisor William Rankin regarding a retaliation complaint by employee Kathy LaSauce, Melton's secretary Laughlin (plaintiff) concluded Melton was covering up Rankin's misconduct and removed the letter and other documents from Melton's desk, photocopied them, and sent copies to LaSauce; Laughlin's conduct came to light during LaSauce's later civil suit, and Metropolitan Washington Airports Authority (MWAA) (defendant) fired Laughlin for removing and releasing confidential documents without authorization. Laughlin sued under Title VII's retaliation provisions, and the district court granted MWAA summary judgment on the theory that deceitful conduct is presumptively unprotected, prompting Laughlin's appeal.