Full opinion text
memorandum: opinion COLLEEN KOLLAR-KOTELLY, District Judge. Pro se Plaintiff, Mohammed Isse, brings this action against his former employer, Defendant American University (“Defendant” or the “University”), pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., alleging that the University unlawfully terminated his employment as a shuttle bus driver because of Plaintiff’s Muslim religion and Somalian national origin. Plaintiffs Complaint also includes a retaliation claim, which Plaintiff has now abandoned, and names as an additional defendant Plaintiffs immediate supervisor at the University, Kevin Wyatt. Defendant has moved for summary judgment, seeking to dismiss this case in its entirety. Upon a searching consideration of the filings currently before the Court, the attached exhibits, the relevant case law, and the entire record herein, the Court concludes that genuine issues of material fact exist as to Plaintiffs unlawful termination claim. The Court shall therefore DENY-IN-PART Defendant’s Motion for Summary Judgment, insofar as it relates to that claim. In so doing, the Court clarifies that Plaintiffs unlawful termination claim represents his sole triable claim; Plaintiff has abandoned his retaliation claim, which the Court shall dismiss, and although Plaintiff alleges that Defendant failed to reasonably accommodate his religious observance, he cannot pursue those allegations as a separate claim. Further, because the Court agrees with Defendant that Plaintiff may not pursue his unlawful termination claim against Mr. Wyatt individually, the Court shall GRANT-IN-PART Defendant’s Motion for Summary Judgment to the extent it relates to Mr. Wyatt individually. I: BACKGROUND The Court begins its discussion of the facts by noting that this Court strictly adheres to the text of Local Civil Rule 56.1 (identical to Local Civil Rule 7(h) (formerly Rule 7.1(h))). The local rules for summary judgment “assist[ ] the district court to maintain docket control and to decide motions for summary judgment efficiently and effectively.” Jackson v. Finnegan, Henderson, Farabow, Garrett & Dunner, 101 F.3d 145, 150 (D.C.Cir.1996). “Requiring strict compliance with the local rule is justified both by the nature of summary judgment and by the rule’s purposes .... The procedure contemplated by the rule thus isolates the facts that the parties assert are material, distinguishes disputed from undisputed facts, and identifies the pertinent parts of the record.” Id. (quoting Gardels v. CIA, 637 F.2d 770, 773 (D.C.Cir.1980)). “[A] district court should not be obliged to sift through hundreds of pages of depositions, affidavits, and interrogatories in order to make [its] own analysis and determination of what may, or may not, be a genuine issue of material fact.” Id. (quoting Twist v. Meese, 854 F.2d 1421, 1425 (D.C.Cir.1988)). In the instant action, the Court has already afforded Plaintiff an extra chance to comply with Local Civil Rule 56.1, guided by the “well-established practice of construing a pro se party’s pleadings liberally.” See United States v. Palmer, 296 F.3d 1135, 1143 (D.C.Cir.2002) (citing Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972) (per curiam)). On August 21, 2007, the Court found that Plaintiffs original “Statement of Material Facts in Dispute” failed to comply with Local Civil Rules 7(h) and 56.1, as well as with this Court’s October 11, 2006 and April 27, 2007 Scheduling and Procedures Orders, which specifically advise the parties that “[t]he Court strictly adheres to the dictates of Local Civil Rules 7(h) and 56.1 and may strike pleadings not in conformity with these rules.” See Isse v. Am. Univ., Civil Action No. 06-1422, Orders (D.D.C. Oct. 10, 2006 and Apr. 27, 2006) (citing Burke v. Gould, 286 F.3d 513, 519 (D.C.Cir.2002)); Isse, Order (D.D.C. Aug. 21, 2007). Alerting Plaintiff as to the purpose and requirements of the Local Civil Rules, the Court struck Plaintiffs Opposition in its entirety and gave Plaintiff another opportunity to file a compliant Statement of Material Facts in Dispute. See Isse, Order (D.D.C. Aug. 21, 2007). Plaintiffs revised Opposition is accompanied by a paragraph-by-paragraph Reply to Defendant’s Statement of Material Facts as to Which There is No Genuine Dispute (“Plaintiffs Reply Statement”), as well as a separate Statement of Material Facts in Dispute (“Plaintiffs Statement”). Plaintiffs Statement and his Statement partially comply with Local Civil Rules 7(h) and 56.1; Plaintiff supports some, but not all, of his factual assertions with specific citations to the factual record. Nevertheless, in light of the fact that Plaintiff is proceeding pro se and has already been given an opportunity to revise his statement, the Court has not attempted to solicit additional record evidence that Plaintiff has failed to provide. Rather, pursuant to Local Civil Rule 56.1, in resolving the present summary judgment motion, the Court “assumes that facts identified by the moving party in the statement of material facts are admitted, unless such a fact is controverted in the statement of genuine issues filed in opposition to the motion.” LCvR 56.1; 7(h). The Court therefore treats as admitted all facts alleged by Defendant that are supported by record evidence and not specifically contradicted by Plaintiff. The Court has also considered the facts adduced by Plaintiff in his Statement, to the extent that they are supported by record evidence, and cites directly to the record, where appropriate, to provide additional information not covered in either of the parties’ statements. A. Plaintiff’s Employment by the University Plaintiff, Mohammed Isse, is a practicing Muslim and a native of Somalia. See Pl.’s Opp’n, Ex. 4 (Isse Aff. ¶¶ 1, 3). Plaintiff worked as a full-time shuttle bus driver in Defendant American University’s Transportation Services Department from approximately 1990 until his termination on September 16, 2005. Def.’s Stmt. ¶ 1; Pl.’s Reply Stmt. ¶ 1. Beginning in January 1999, Plaintiffs direct supervisor was Kevin Wyatt, the University’s Shuttle Operations Coordinator. Def.’s Stmt. ¶ 2; PL’s Reply Stmt. ¶2; Def.’s Ex. 3 (5/30/07 Wyatt Decl.) ¶ 2. Since August 2004, Mr. Wyatt has reported to Anthony Newman, the University’s Director of Risk Management and Transportation Services. Def.’s Stmt. ¶ 2; PL’s Reply Stmt. ¶ 2; Def.’s Ex. 1 (5/29/07 Newman Decl.) ¶¶ 1-2. Before reporting to Mr. Newman, Mr. Wyatt reported to Thomas Leathers, who was employed in the Transportation Services Department from June 1995 until July 2004. Def.’s Stmt. ¶2; PL’s Reply Stmt. ¶ 2; Def.’s Ex. 3 (5/30/07 Wyatt Decl.) ¶ 2. The University adheres to a progressive discipline policy, which provides “guidelines” for supervisors to follow in taking disciplinary action. Def.’s Ex. 9 (Disciplinary Policy-Revised May 2005) at 51; Def.’s Stmt. ¶ 8; PL’s Reply Stmt. ¶ 8. The disciplinary policy categorizes employee offenses as Level I, Level II, and Level III offenses, with Level III offenses being the most severe and usually warranting immediate dismissal. Def.’s Ex. 9 (Disciplinary Policy) at 51-53; Def.’s Stmt. ¶ 8; PL’s Reply Stmt. ¶ 8. Three Level II offenses generally warrant dismissal under the policy. Id. According to Mr. Newman, since becoming Director of Transportation Services, he has generally treated safety violations by shuttle drivers as Level II offenses. Def.’s Ex. 1 (5/29/07 Newman Decl.) ¶ 9. The record only contains Plaintiffs last two performance evaluations, from 2004 and 2005, both of which were completed by Mr. Wyatt. See Def.’s Exs. 40 and 41 (Isse Perf. Evals). Although Plaintiffs 2005 evaluation notes the disciplinary warnings that Plaintiff received during that year (which are discussed in great detail below), Defendant describes each evaluation as satisfactory, and Plaintiff so described them in his Complaint. Def.’s Stmt. ¶ 4; Compl. ¶ 9. B. Plaintiffs Complaints Regarding His Supervisors Over the course of his employment, Plaintiff filed numerous written complaints with members of the University’s Human Resources and Risk Management staffs. Def.’s Stmt. ¶ 20; Pl.’s Reply Stmt. ¶ 20. Plaintiff specifically complained about an altercation with another employee, see Def.’s Ex. 27 (9/14/98 Mem. re: Investigation of ComplainNM. Isse); inadequate pay, his evaluations, delayed payment of a bill for a drug test, and Mr. Wyatt’s refusal to help Plaintiff clean his bus, see Def.’s Ex. 22 (1/30/02 Letter from M. Isse to B. Harner); perceived favoritism towards other employees, see Def.’s Ex. 23 (3/27/03 Letter from M. Isse to M. Muha); an oral warning Plaintiff received for an unplanned absence, see Dei’s Ex. 28 (4/5/05 Letter from G. Karmiol to M. Isse) and Def.’s Ex. 29 (2/1/05 Letter from Plaintiffs attorney to K. Wyatt); and a written warning Plaintiff received for leaving his bus during a shift, see Def.’s Ex. 28 (4/5/05 Letter from G. Karmiol to M. Isse) and Def.’s Ex. 30 (2/3/05 Letter from Plaintiffs attorney to K. Wyatt). In two of those written complaints, Plaintiff made general references to feeling discriminated against on the basis of his religion and national origin. See Def.’s Ex. 22 (1/30/02 Letter from M. Isse to B. Harner) (“I feel that I am being discriminated against perhaps because I am an immigrant. I am also sensitive to the religious factor, as I am a Muslim.”); Def.’s Ex. 23 (3/27/03 Letter from M. Isse to M. Muha) (“I reported in January what I felt was discrimination on the basis of national origin and religion at my workplace ... I feel that discrimination and psychological harassment persists.”). Plaintiff did not, however, describe any specific incidents that bear an obvious connection to his religion or national origin. Def.’s Exs. 22 and 23. In particular, Plaintiffs 2002 and 2003 letters did not include complaints about either an alleged refusal by Mr. Wyatt to accommodate Plaintiffs request to schedule his lunch breaks on Fridays so that he could attend Muslim prayer sessions, or about allegedly anti-Muslim/anti-Somalian comments made by Mr. Wyatt. Def.’s Stmt. ¶ 19; Def.’s Exs. 22 and 23. Nevertheless, as discussed below, it is clear that Plaintiff alleges as much at this point in time. 1. Friday Prayer Sessions According to Plaintiff, “[o]n many occasions, on a regular basis during my employment at American University, defendant Kevin Wyatt refused to allow me to attend Friday Muslim prayers.” Pl.’s Stmt. ¶ 1; Pl.’s Ex. 4 (Isse Aff.) ¶ 1. Although Plaintiffs evidence in support of this allegation is somewhat muddled, it is clear that a factual dispute exists as to whether Mr. Wyatt, in fact, acceded to Plaintiffs request for a religious accommodation. Plaintiff supports his assertion with the affidavit of Ron Crowder, a former part-time bus driver at the University, who states that “Mr. Wyatt discriminated against Mr. Isse because of his religion; he did not let him pray all the time,” PL’s Ex. 1 (8/13/07 Crowder Aff.) ¶ 6, as well as the affidavit of Will Spencer, who worked in the same building as the Transportation Services Department, and states that he “observed discrimination against Mr. Isse on a regular basis. Mr. Isse’s prayer times were on Friday, and he was either denied the right to pray and/or he was not given enough time to do so,” PL’s Ex. 2 (8/14/07 Spencer Aff.) ¶ 3. Plaintiff does not proffer any evidence of how frequently he was unable to attend Friday prayer sessions, and his deposition testimony on this subject is highly inconsistent. See Def.’s Ex. 26 (Isse Dep.) at 42:18-22 (“I missed them at least, at least 20 times” in four months); 43:1-10 (“like, 10 times” in 2004); 43:11-21 (“In 2003,1 missed them a lot of times ... Monthly, I missed like three times or two times.”); 45:17-18 (“At least monthly I missed four, three times, two times, or one time.”). Plaintiffs testimony is also inconsistent as to when he first encountered difficulty attending Friday prayers. Id. at 29:5-7; 31:1-19 (“Since Thomas Leathers came into the Department, [in 1995,] I have a difficult time.”); 31:10-15 (indicating difficulty attending prayers in 2002 but not 2001); 241:10-242:14 (indicating difficulty attending prayers from 2000 through 2005). Despite these inconsistencies, the gist of Plaintiffs testimony is clearly that Mr. Wyatt repeatedly denied Plaintiffs requests to schedule his Friday lunch break around Muslim prayer sessions. This allegation is strongly contested in Mr. Wyatt’s Declaration. According to Mr. Wyatt, soon after becoming Shuttle Operations Coordinator, he “became aware that Mr. Isse was a practicing Muslim and wanted to continue to attend Friday prayer sessions ... between 1:10 and 2:10 each Friday.” Def.’s Ex. 3 (5/30/07 Wyatt Decl.) ¶ 4. Mr. Wyatt further avers: I acknowledged Mr. Isse’s request, told him I would accommodate it, and planned Friday lunch schedules so that Mr. Isse’s lunch break would correspond with Friday prayer sessions. This accommodation required rearranging the regular schedule to allow Mr. Isse to take his lunch break outside of the normal lunch break period [which runs from 9:30 a.m. to 12:50 p.m. and includes staggered breaks based upon the driver’s assigned route]. This accommodation was well known to the other drivers within the department since Mr. Isse was the only driver whose lunch break was at the same time and not dependent upon the assigned route. Id. ¶¶ 3, 5. Mr. Wyatt continues to state, “[o]ver roughly the six year period that I supervised Mr. Isse, I am aware of only one Friday prayer session which Mr. Isse could not attend because I could not accommodate his schedule.” Id. ¶ 6. Mr. Wyatt asserts that Plaintiff never complained to him about not being able to attend Friday prayers and that he only remembers Plaintiff being upset when he could not attend the one Friday prayer session due to a scheduling difficulty. Id. ¶ 7. Finally, Mr. Wyatt avers that he did not learn of Plaintiffs complaints regarding Friday prayers until Plaintiff appealed his termination in September 2005. Id. Other than Mr. Wyatt’s Declaration, Defendant does not proffer any evidence of how frequently Plaintiff was able to attend Friday prayer sessions. Instead Defendant focus on Plaintiffs admission that he was able to attend Friday prayers at times. See Def.’s Stmt. ¶ 3. Notwithstanding this undisputed fact, there is a genuine dispute as to how frequently Plaintiff was able to attend Friday prayers, and how willingly Mr. Wyatt accommodated Plaintiffs request to schedule his Friday lunch break around prayer sessions. 2. Allegations of Anti-Muslim and Anti-Somalian Comments There is also a clear factual dispute as to whether Mr. Wyatt and his former supervisor, Mr. Leathers, made various comments that Plaintiff describes as anti-Muslim or anti-Somalian. For his part, Mr. Wyatt avers, “I am aware that Mr. Isse claims that ... I and Mr. Thomas Leathers made comments derogatory to Muslims. I did not say any of the things attributed to me by Mr. Isse, nor have I made other comments derogatory to Muslims.” Def.’s Ex. 3 (5/30/07 Wyatt Deck) ¶ 17. In contrast, Plaintiff proffers his own affidavit, in which he avers that “Defendant Kevin Wyatt said things to me like I should change my name after September 11th, asking why we Muslims do that in reference to bombings in Iraq, ... mentioned terrorism and directed those comments to me and others.” Pl.’s Ex. 4 (Isse Aff.) ¶ 2. According to Plaintiff, the “comments about my religion and where I am from (Somalia) by Defendant Wyatt became worse after [September 11, 2001].” Id. ¶ 3. During his deposition, Plaintiff also testified that Mr. Wyatt and Mr. Leathers made various comments, including “you’re a nice guy, but you’ve got to change your name, man. Terrorists, they’re looking] for Mohamed or Ahmed or something like that,” and “change your name otherwise you’re going back to your country.” Def.’s Ex. 26 (Isse Dep.) at 78:9-81:15. According to Plaintiff, Mr. Wyatt and Mr. Leathers told him that Somalia was on a list of countries associated with terrorism, and asked Plaintiff “What’s wrong with you people?” “when something happen in, like, Iraq or anything.” Id. at 81:20-84:5. While the record is far from clear as to precisely what comments Plaintiff alleges Mr. Wyatt made and when, it is obvious that a factual dispute exists as to whether Mr. Wyatt made comments that could be perceived as anti-Muslim or anti-Somalian. C. Events Leading to Plaintiffs September 2005 Termination Significant factual disputes also abound with respect to the events leading up to the termination of Plaintiffs employment with the University in September 2005. Plaintiffs termination was precipitated by complaints regarding Plaintiffs “reckless driving from university staff members,” which led to two disciplinary warnings. See Def.’s Ex. 17 (9/16/05 Term. Letter). Plaintiff denies being involved in the incidents for which he received the two disciplinary warnings, and disputes key facts regarding the third incident. The Court addresses each in turn. 1. April 8, 2005 Warning At various staff meetings in late 2004 and early 2005 — -and in particular on March 1, 2005 — Mr. Newman and Mr. Wyatt instructed all shuttle drivers that it is unsafe and against University policy to let passengers off of the bus where there is no designated shuttle stop. Def.’s Stmt. ¶ 6; Def.’s Ex. 1 (5/29/07 Newman Deck) ¶ 4; Def.’s Ex. 3 (5/30/07 Wyatt Deck) ¶ 8; Def.’s Ex. 6 (5/30/07 N. Porter Deck) ¶ 2; Def.’s Ex. 7 (5/30/07 E. Weddle Deck) ¶2. Plaintiff does not dispute being present when such warnings were given. See Ph’s Reply Stmt. ¶ 6. On April 4, 2005, Tanisha Jagoe, the University’s Director of Business Compliance, reported to Mr. Newman that while riding on a shuttle bus driven by Plaintiff that morning she observed Plaintiff allowing two passengers to disembark while the bus was stopped at traffic lights where there were no designated shuttle stops. Def.’s Stmt. ¶ 5; Def.’s Ex. 4 (5/29/07 Ja-goe Deck) ¶¶ 2-5; Def.’s Ex. 5 (4/4/05 email from T. Jagoe to A. Newman). Defendant proffers Ms. Jagoe’s Declaration, in which she avers that she has been a regular rider of the University’s shuttle buses since August 2004, that she was riding the 11:10 shuttle between the University’s Main Campus and the Tenley-town Metro stop (the “Metro 1 bus”) on April 4, 2005, and that she “recognized the driver of the ... shuttle bus [in question] as Mohammed Isse. I was familiar with Mr. Isse because I had often ridden on shuttle buses operated by him.” Def.’s Ex. 4 (Jagoe Deck) ¶¶ 2-4. Defendant also proffers Ms. Jagoe’s April 4, 2005 email to Mr. Newman reporting the incident, in which Ms. Jagoe states, “I believe Mohammed was driving,” and refers to “Mohammed” letting passengers off. Def.’s Ex. 5 (4/4/05 e-mail from T. Jagoe to A. Newman). After receiving Ms. Jagoe’s e-mail, Mr. Newman spoke with Mr. Wyatt, who reported to Mr. Newman that he checked his records and confirmed that Plaintiff was the scheduled relief driver on the Metro 1 bus that Ms. Jagoe reported riding when she observed the unauthorized stops. Def.’s Stmt. ¶ 5; Def.’s Ex. 1 (Newman Decl.) ¶ 7; Def.’s Ex. 3 (Wyatt Decl.) ¶ 12. Mr. Newman then “instructed Mr. Wyatt to draft a disciplinary memorandum for ‘a Level II documented oral warning’ for willful violations of safety rules.” Def.’s Ex. 1 (Newman Decl.) ¶ 9; Def.’s Ex. 3 (Wyatt Decl.) ¶ 13; Def.’s Stmt. ¶ 7. After consulting with the University Human Resources department, Mr. Newman advised Mr. Wyatt to issue the disciplinary memorandum to Plaintiff. Def.’s Ex. 1 (Newman Decl.) ¶ 9; Def.’s Ex. 3 (Wyatt Decl.) ¶ 13; Def.’s Stmt. ¶ 7. The disciplinary memorandum, dated April 8, 2005, is entitled “AU Staff Policy Level II Violation: Willful Violation of Safety Rules,” describes Ms. Jagoe’s account of the April 4, 2005 incident, and states that “[a]ny future violations will result in further disciplinary actions including termination.” Def.’s Ex. 8 (4/8/05 Mem. from K. Wyatt to M. Isse). Plaintiff maintains that he “never dropped off passengers at unauthorized stops,” PL’s Reply Stmt. ¶ 5, and during his deposition testified that he was driving a law school route bus — rather than the Metro 1 bus — on April 4, 2005. Def.’s Ex. 26 (Isse Dep.) at 121:8-122:2. As such, there is a clear factual dispute between Mr. Wyatt’s contention that Plaintiff was the scheduled relief driver for the Metro 1 bus, see Def.’s Ex. 3 (Wyatt Decl.) ¶ 12, and Plaintiffs assertion that he was not driving the bus in question. The Court notes that Defendant has not proffered documentary evidence, such as a schedule or route sheet, in support of Mr. Wyatt’s claim that Plaintiff was the scheduled relief driver. 2. July 26, 2005 Warning On July 11, 2005, William Suter, the University’s Director of Physical Plant Operations, observed shuttle bus # 160 turn into the University’s main campus without using a turn signal and run a stop sign. Def.’s Stmt. ¶ 9; Def.’s Ex. 1 (Newman Decl.) ¶ 10; Def.’s Ex. 10 (7/19/05 email from W. Suter to A. Newman). According to Mr. Newman, Mr. Suter reported the incident to Mr. Newman verbally on July 11, 2005 and then put his complaint in writing in an e-mail dated July 19, 2005. Def.’s Ex. 1 (Newman Decl.) ¶ 10; Def.’s Ex. 10 (7/19/05 e-mail). Mr. Newman reported the incident to Mr. Wyatt and asked Mr. Wyatt to determine who was assigned to drive bus # 160 on the day in question. Def.’s Ex. 1 (Newman Decl.) ¶ 10; Def.’s Ex. 3 (Wyatt Decl.) ¶ 14; Def.’s Stmt. ¶ 9. Mr. Wyatt avers that his “records showed that Mr. Isse was assigned to drive bus # 160,” and that he “secured a Citgo gas receipt signed by Mr. Isse showing that [Plaintiff] had purchased gas that morning” for bus # 160. Def.’s Ex. 3 (Wyatt Decl.) ¶ 14. That gas receipt does not identify the time that the gas was purchased. See Def.’s Ex. 11 (7/11/05 Cit-go receipt). Based on the information provided by Mr. Wyatt, Mr. Newman “consulted with the University’s Human Resources Department,” and “[w]ith HR approval, [] instructed Mr. Wyatt to issue a formal disciplinary warning (‘Level II Written Warning’) to Mr. Isse ... for ‘careless, reckless, and slipshod work.’ ” Def.’s Ex. 1 (Newman Decl.) ¶ 10; Def.’s Ex. 3 (Wyatt Decl.) ¶ 14; Def.’s Stmt. ¶ 10. The resulting July 26, 2005 disciplinary memorandum is entitled “Level II Written Warning: Careless, Reckless, or Slipshod Work,” describes Mr. Suter’s account of the July 11, 2005 incident, and states that “[a]ny repetition of this behavior or other violations of university policy will result in additional disciplinary action up to and including termination of employment.” Def.’s Ex. 12 (7/26/05 Mem. from K. Wyatt to M. Isse); Def.’s Ex. 3 (Wyatt Decl.) ¶ 14; Def.’s Stmt. ¶ 10. Plaintiff maintains that he “was not driving the bus at the time and did not do what was alleged by Mr. William Suter,” who Plaintiff notes did not actually identify the driver of the # 160 bus. PL’s Reply Stmt. ¶ 9. According to Plaintiff, on July 11, 2005, he picked up the # 160 bus at approximately 6:10 a.m., drove to the gas station and filled the bus, and returned the bus to a shuttle stop on the University’s main campus at approximately 6:40 a.m. See Def.’s Ex. 14 (8/9/05 Mem. from M. Isse to A. Newman); Def.’s Ex. 26 (Isse Dep.) at 126:2-128:1. Plaintiff asserts that he left the bus at the shuttle stop, went to move his car, and returned to the University, where he went inside to change into his uniform. Id. According to Plaintiff, at 7:00 a.m., he was driving the # 160 bus out of the University’s main campus, rather than entering the main campus as Mr. Suter reported. Id. Plaintiff therefore asserts that someone else must have been driving the # 160 bus when Mr. Suter observed it entering the main campus, and speculates that a mechanic might have been testing the bus before Plaintiff took it out for the day. Id. According to Plaintiff, mechanics did not always inform drivers before taking buses out in the morning, and no one told him they were taking the # 160 bus out on the morning of July 11, 2005. Def.’s Ex. 26 (Isse Dep.) at 127:1-13. As with the April 4, 2005 incident, a clear factual dispute exists based on Plaintiffs assertion that he was not driving the bus when Mr. Suter observed it. On August 4, 2005, Plaintiff met with Mr. Newman. Def.’s Ex. 1 (Newman Decl.) ¶ 12. According to Mr. Newman, Plaintiff “contested his prior disciplinary notices and described numerous purported improprieties in the department but [ ] did not allege discrimination.” Id. Mr. Newman’s account of the August 4, 2005 meeting is supported by an August 8, 2005 memorandum that Mr. Newman states he wrote to document his conversation with Plaintiff. Id.\ Def.’s Ex. 13 (8/8/05 Mem. from A. Newman to M. Isse). On August 9, 2005, Plaintiff submitted a written complaint to Mr. Newman, seeking removal of the April 8, 2005 and July 26, 2005 disciplinary warnings. Def.’s Ex. 14 (8/9/05 Mem. from M. Isse to A. Newman). Plaintiff asserted that he was not driving the Metro 1 route on April 4, 2005, and that he was not driving the # 160 bus at the time when Mr. Suter observed it entering the University’s main campus. Id. Plaintiff further stated, “I feel like I was targeted because of racial, religious, and ethnic discrimination,” and “I feel like I am being unjustly and unfairly targeted by Kevin Wyatt in retaliation for being honest and forthcoming about corrupt practices at the workplace.” Id. Plaintiff copied his complaint to the University’s Executive Director of Human Resources, Beth Muha, as well as the Executive Director of Risk Management, Pat Kelshian. Id. Mr. Newman reviewed Plaintiffs complaint with Ms. Muha and Ms. Kelshian, and “concluded that both warnings were justified based upon eyewitness reports by two individuals outside the department, including Ms. Jagoe who identified Mr. Isse as the driver of the first incident.” Def.’s Ex. 1 (Newman Decl.) ¶ 13. Mr. Newman, “also found persuasive the fact that Mr. Isse was assigned to drive bus # 160 on July 11 and there existed a gas receipt signed by Mr. Isse which placed him with the bus that same morning.” Id. Mr. Newman therefore sent Plaintiff an August 23, 2005 memorandum informing Plaintiff of his decision to uphold the two disciplinary warnings. Id.-, Def.’s Ex. 15 (8/23/05 Mem. from A. Newman to M. Isse). Mr. Newman stated that he felt “confident the reprimands are justified,” and that “the write-ups were issued neither in retaliation nor due to racial, religious or ethnic discrimination as you allege.” Id. 3. September 16, 2005 Termination On September 15, 2005, Ms. Jagoe reported to Mr. Newman that, while riding metro route shuttle buses driven by Plaintiff on the mornings of September 14 and 15, she observed Plaintiff making a left turn onto Wisconsin Avenue from Grant Road, where there is no traffic light, rather than from Albemarle Street, where there is a traffic light. Def.’s Stmt. ¶ 11; Pl.’s Reply Stmt. ¶ 11; Def.’s Ex. 16 (9/15/05 e-mail from T. Jagoe to K. Wyatt). Ms. Jagoe further reported that, in turning from Grant Road, Plaintiff blocked five lanes of traffic and honked his horn at other drivers at least eight times. Id. According to Defendant, shuttle drivers were specifically instructed in an April 11, 2005 “Route Summary” memorandum to use Albemarle Street when returning to the University’s main campus from the Tenleytown Metro stop. Def.’s Stmt. ¶ 12; Def.’s Ex. 18 (4/11/05 Route Summ. Mem.); Def.’s Ex. 1 (Newman Decl.) ¶ 5; Def.’s Ex. 3 (Wyatt Decl.) ¶ 9. The Route Summary memorandum that Defendant proffers specifically states “NO Shuttle operator can change or deviate from the normal/regular shuttle routes without prior approval from Kevin [Wyatt] and/or Tony Newman FIRST. Failure to follow this guideline will result in disciplinary actions.” Def.’s Ex. 18 (Route Summ. Mem.) (emphasis in original). Defendant also proffers the Declarations of two other shuttle bus drivers who recall Mr. Wyatt distributing the Route Summary memorandum to all drivers on approximately April 11, 2005, and specifically stating to drivers that they were to take Albemarle Street rather than Grant Road and were not to deviate from the route without prior permission. Def.’s Ex. 6 (Porter Decl.) ¶ 4; Ex. 7 (Weddle Decl.) ¶ 4. Those drivers also “recall discussing the issue with several drivers including Mr. Isse around the same time period” and state that “Mr. Isse was well aware of the proper shuttle routes and the fact that drivers were not allowed to deviate from these routes without approval from Mr. Newman or Mr. Wyatt.” Def.’s Ex. 6 (Porter Decl.) ¶ 5; Ex. 7 (Weddle Decl.) ¶ 5. On April 11, 2005, Mr. Newman also instructed Mr. Wyatt to post a notice on a bulletin board within the Transportation Services Department. Def.’s Stmt. ¶ 13; PL’s Reply Stmt. ¶ 13; Def.’s Ex. 1 (Newman Decl.) ¶ 7; Def.’s Ex. 3 (Wyatt Decl.) ¶ 9. The notice stated: “Attention all shuttle operators: as of April 11, 2005 DO NOT deviate off of the normal routes for any reasons except you have prior approval from Wyatt or Newman first. Stay on Nebraska Ave. for the Metro and WCL Direct routes.” Def.’s Ex. 19 (4/11/05 Notice) (emphasis in original). Plaintiff admits having seen the notice in April 2005. PL’s Reply Stmt. ¶ 13; Def.’s Ex. 26 (Isse Dep.) at 176:2-178:18. Plaintiff also admits that on September 15, 2005 he took the left turn onto Wisconsin Avenue from Grant Road, rather than Albe-marle Street (although he denies the remainder of Ms. Jagoe’s description of his driving that day). PL’s Reply Stmt. ¶ 11. However, Plaintiff denies having been told that the approved Metro shuttle route used Albemarle Street rather than Grant Road. Id. ¶ 14. During his deposition, Plaintiff testified variously that Mr. Wyatt told Plaintiff and other shuttle bus drivers that they could take Grant Avenue and that Mr. Wyatt was aware that shuttle bus drivers were using Grant Avenue and did not tell them not to do so. Def.’s Ex. 26 (Isse Dep.) at 150:9-157:21. According to Plaintiff, he did not deviate from the normal route without prior approval because his Grant Road route was a “normal route.” Pl.’s Reply Stmt. ¶ 14; Def.’s Ex. 26 (Isse Dep.) at 138:19-21. Plaintiff specifically denies receiving the April 11, 2005 Route Summary memorandum, PL’s Reply Stmt. ¶ 12; PL’s Ex. 4 (Isse Aff.) ¶¶ 10-11, and during his deposition, speculated that the Route Summary memorandum was created after his termination, Def.’s Ex. 26 (Isse Dep.) at 184:2-193:14. Plaintiff offers no support for this assertion, other than his contention that he did not see it until after he filed his EEOC charge. 7d Nevertheless, a factual question clearly exists as to whether Plaintiff was aware, as of September 2005, that the only approved Metro shuttle route ran via Albemarle Street rather than Grant Road. In any event, after receiving Ms. Jagoe’s e-mail on September 15, 2005, and believing that Plaintiffs use of Grant Road constituted an unapproved route deviation, Mr. Newman asked Mr. Wyatt to meet with Plaintiff and get Plaintiffs explanation for using Grant Road. Def.’s Ex. 1 (Newman Decl.) ¶ 15; Def.’s Ex. 3 (Wyatt Decl.) ¶ 16. According to Mr. Wyatt, Plaintiff “denied taking Grant Road or otherwise deviating from approved routes,” and stated that he believed other drivers were using Grant Road. Def.’s Ex. 3 (Wyatt Deck) ¶ 13. As a result, Mr. Wyatt reports interviewing several other shuttle operators to determine whether they were using Grant Road. Id. According to Mr. Wyatt, all other drivers responded that they had only used Albemarle Street since being told not to use Grant Road during staff meetings. Id.; see also Def.’s Ex. 20 (9/15/05 e-mail from K. Wyatt to A. Newman). Mr. Wyatt reported his findings to Mr. Newman, and the two “discussed the matter and agreed that based upon Ms. Jagoe’s report and Mr. Isse’s prior disciplinary record, Mr. Isse should be terminated.” Def.’s Ex. 3 (Wyatt Deck) ¶ 16, Def.’s Ex. 1 (Newman Deck) ¶ 15. Mr. Newman then discussed the decision to terminate Plaintiff with Ms. Kelshian and with Grace Karmiol, Director of Policy and Regulatory Affairs in the University’s Human Resources Department. Def.’s Ex. 1 (Newman Decl.) ¶¶ 15-16. Ms. Kels-hian concurred in the decision, and Ms. Karmiol drafted the termination memorandum on Mr. Newman’s behalf. Id. Ms. Karmiol also advised Mr. Newman that one of her staff members, Ms. Harner, reported being on Plaintiffs bus on the morning of September 15 and could corroborate Ms. Jagoe’s complaint. Id. ¶ 16; see also Def.’s Reply Ex. B (9/20/07 Har-ner Decl.). After that conversation, Mr. Newman instructed Mr. Wyatt to terminate Plaintiffs “employment effective September 16, 2005 for careless and slipshod work, willful violation of safety rules and insubordination.” Def.’s Ex. 1 (Newman Decl.) ¶ 16. Mr. Wyatt’s September 16, 2005 termination memorandum describes Ms. Jagoe’s complaint, the safety risk posed by turning from Grant Avenue, and the April 8, 2005 and July 26, 2005 warnings that Plaintiff received. See Def.’s Ex. 17 (9/16/05 Mem. from K. Wyatt to M. Isse). The memorandum further explains that Plaintiffs alleged insubordination consisted of disregarding specific instructions not to deviate from the approved route, and states that Plaintiff made a misrepresentation when he told Mr. Wyatt that he had not deviated from the approved route. Id. Significantly, Plaintiff altogether denies speaking to Mr. Wyatt on September 15, 2005, Pl.’s Ex. 4 (Isse Aff.) ¶ 13, thus creating another genuine factual dispute. On September 26, 2005, Plaintiff filed a written appeal of his termination to the University’s Staff Personnel Review Board (“Review Board”). Def.’s Ex. 21 (9/26/05 Appeal of Term.). Plaintiff denied receiving the April 11, 2005 Route Summary memorandum, as well as any involvement in the incidents underlying in the April 8, 2005 and July 26, 2005 disciplinary memo-randa. Id. Plaintiffs appeal also states, “I was terminated by my supervisor Kevin Wyatt in retaliation for my disclosures and complaints about racial and religious discrimination. I also suspect that my termination was timed to occur before I could talk to Pat Kelshian.” Id. The Review Board appointed a Hearing Panel of three University administrators from other departments, who held a hearing on Plaintiffs appeal. Def.’s Stmt. ¶ 18; Def.’s Ex. 31 (10/14/05 Letter from G. Karmiol to M. Isse); Def.’s Ex. 32 (11/28/05 Mem. from M. Mikkelsen to I. Broder). On November 17, 2005, the Hearing Panel voted to recommend to the University’s Acting Provost that she affirm Plaintiffs termination and dismiss his appeal. Id. In a memorandum to Acting Provost Broder regarding Plaintiffs appeal, the Chair of the Review Board stated: Based upon the evidence presented by Mr. Newman and Mr. Wyatt at the Hearing, the [Review Board] concluded that on April 4, 2005 at 11:15 am, Mr. Isse was driving the Metro 1 bus; on July 26, 2005 at 7:00 am that Mr. Isse was driving bus # 160 entering through Fletcher Gate; and on or around September 16, Mr. Isse did deviate from the approved route from Tenley Metro stop to the [University] campus. We found that [Mr. Isse’s] termination was unrelated to his complaints of racial and religious discrimination. Id. The University’s Acting Provost affirmed the Review Board’s recommendation that Plaintiffs termination be upheld. Def.’s Stmt. ¶ 21; Def.’s Ex. 33 (11/29/05 Mem. from G. Karmiol to I. Broder); Def.’s Ex. 34 (12/9/05 Letter from G. Kar-miol to M. Isse). D. Plaintiffs Allegations of Disparate Discipline In his written appeal of his termination Plaintiff asserted, “I feel like I am being unfairly targeted because other drivers have also been taking Grant Avenue and making a left turn from there,” but does not identify the alleged “other drivers.” Defi’s Ex. 21 (9/26/05 Appeal of Term.). During his deposition, Plaintiff identified various drivers whom he alleges used Grant Road or ran stop signs. See Def.’s Ex. 26 (Isse Dep.) at 242:17-254:20; 255:7-258:5. However, Plaintiff admits that he has no knowledge of other drivers’ disei-plinary histories. Id. Further, while Plaintiff testified during his deposition that he informed Mr. Wyatt of at least two drivers’ alleged safety violations, his testimony in this respect is unclear at best, and he does not proffer evidence that either Mr. Wyatt or Mr. Newman was aware of many of the violations he alleges. Id. In contrast to Plaintiffs allegations of disparate discipline, Defendant proffers a list of other University shuttle drivers who have been terminated for safety violations, including failing to secure a bus that crashed into a parked car; driving recklessly and under suspicion of driving under the influence; and leaving a running bus unattended. Def.’s Stmt. ¶ 17; Def.’s Ex. 1 (Newman Decl.) ¶ 17; Def.’s Ex. 39 (list of terminated shuttle drivers). Plaintiff does not dispute that other drivers have been terminated for safety infractions, but argues that the infractions for which they were terminated are “grossly unpropor-tional” to the violations for which he was disciplined. Pl.’s Reply Stmt. ¶ 17. In addition, Mr. Newman avers that other University shuttle drivers have received Level II warnings for safety infractions such as driving an overcrowded bus and failing to give the right of way to another driver. Def.’s Stmt. ¶ 17; Def.’s Ex. 1 (Newman Decl.) ¶ 17. Plaintiff does not dispute this assertion. PL’s Reply Stmt. ¶ 17. E. Procedural History Plaintiff filed an EEOC charge against the University on January 4, 2006, which identified religion, age, and national origin — but not retaliation — as “causefs] of discrimination.” Def.’s Stmt. ¶ 22; PL’s Reply Stmt. ¶ 22; Def.’s Ex. 35 (1/4/06 EEOC Charge). The narrative portion of Plaintiffs charge does not allege that he was terminated for either his complaints to Human Resources or for requesting a religious accommodation. IcL; Def.’s Stmt. 1Í 23; PL’s Reply Stmt. ¶23. On May 9, 2006, the EEOC issued Plaintiff a “Dismissal and Notice of Rights” stating that the agency was “unable to conclude” from its investigation of Plaintiffs charge “that the information obtained establishes a violation of the statutes.” Def.’s Ex. 36 (5/9/06 Dismissal and Notice); Def.’s Stmt. ¶ 24; PL’s Reply Stmt. ¶ 24. Plaintiff filed his Complaint in this action on August 10, 2006. II: LEGAL STANDARDS A party is entitled to summary judgment if the pleadings, depositions, and affidavits demonstrate that there is no genuine issue of material fact in dispute and that the moving party is entitled to judgment as a matter of law. See Fed.R.Civ.P. 56(c); Tao v. Freeh, 27 F.3d 635, 638 (D.C.Cir.1994). Under the summary judgment standard, Defendant, as the moving party, bears the “initial responsibility of informing the district court of the basis for [its] motion, and identifying those portions of the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits which [it] believe[s] demonstrate the absence of a genuine issue of material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). Plaintiff, in response to Defendants’ motion, must “go beyond the pleadings and by [his] own affidavits, or depositions, answers to interrogatories, and admissions on file, ‘designate’ specific facts showing that there is a genuine issue for trial.” Id. at 324, 106 S.Ct. 2548 (internal citations omitted). Although a court should draw all inferences from the supporting records submitted by the nonmoving party, the mere existence of a factual dispute, by itself, is not sufficient to bar summary judgment. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). To be material, the factual assertion must be capable of affecting the substantive outcome of the litigation; to be genuine, the issue must be supported by sufficient admissible evidence that a reasonable trier-of-fact could find for the non-moving party. Laningham v. U.S. Navy, 813 F.2d 1236, 1242-43 (D.C.Cir.1987); Liberty Lobby, 477 U.S. at 251, 106 S.Ct. 2505 (the court must determine “whether the evidence presents a sufficient disagreement to require submission to a [fact-finder] or whether it is so one-sided that one party must prevail as a matter of law”). “If the evidence is merely colorable, or is not sufficiently probative, summary judgment may be granted.” Liberty Lobby, 477 U.S. at 249-50, 106 S.Ct. 2505 (internal citations omitted). “Mere allegations or denials in the adverse party’s pleadings are insufficient to defeat an otherwise proper motion for summary judgment.” Williams v. Callaghan, 938 F.Supp. 46, 49 (D.D.C.1996). The adverse party must do more than simply “show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). Instead, while the movant bears the initial responsibility of identifying those portions of the record that demonstrate the absence of a genuine issue of material fact, the burden shifts to the non-movant to “come forward with ‘specific facts showing that there is a genuine issue for trial.’ ” Id. at 587, 106 S.Ct. 1348 (citing Fed.R.Civ.P. 56(e)) (emphasis in original). Importantly, “[w]hile summary judgment must be approached with specific caution in discrimination cases, a plaintiff is not relieved of her obligation to support her allegations by affidavits or other competent evidence showing that there is a genuine issue for trial.” Morgan v. Fed. Home Loan Mortgage Corp., 172 F.Supp.2d 98, 104 (D.D.C.2001), aff'd, 328 F.3d 647 (D.C.Cir.2003); see also Marshall v. James, 276 F.Supp.2d 41, 47 (D.D.C.2003) (special caution “does not eliminate the use of summary judgment in discrimination cases”) (citing cases). “Summary judgment is not a ‘disfavored procedural shortcut,’ but is an integral procedural tool which promotes the speedy and inexpensive resolution of every case.” Marshall, 276 F.Supp.2d at 47 (quoting Celotex Corp., 477 U.S. at 327, 106 S.Ct. 2548). Ill: DISCUSSION Plaintiffs Complaint includes two claims: Count One asserts that Defendant unlawfully terminated him because of his religion, in violation of Title VII, see Compl. ¶¶ 15-17; Count Two asserts that Plaintiff was terminated in retaliation for requesting a reasonable accommodation of his religion, id. ¶¶ 18-24. However, in a Notice filed along with his Opposition, Plaintiff stated that he would “not pursue his claims for retaliation or for age and race discrimination but pursues this matter only on religious and national origin discrimination.” See Pl.’s Notice and Opp’n to Def.’s Mot. for Summ. J. Notwithstanding his asserted “effort to narrow the issues,” id., Plaintiffs Opposition includes various allegations not strictly confined to his claim of unlawful termination on the basis of religion or national origin. As a result, and in light of the fact that Plaintiff is proceeding pro se in this action, the Court initially clarifies that Plaintiff may only pursue that limited claim in this action. The Court then continues to consider Defendant’s Motion for Summary Judgment with respect to that claim, ultimately concluding that genuine issues of material fact preclude summary judgment. A. Plaintiffs Unlawful Termination Claim Represents His Sole Triable Claim In addition to Defendant, American University, Plaintiffs Complaint names Mr. Wyatt as an individual party defendant to this action. See Compl., Caption. Pursuant to D.C. Circuit law, however, an individual may only be sued under Title VII in his or her official capacity. See Gary v. Long, 59 F.3d 1391, 1399 (D.C.Cir.1995). Moreover, a claim against Mr. Wyatt in his official capacity would essentially “merge” into Plaintiffs action against the University. Id. As such, the Court shall dismiss Mr. Wyatt as a party defendant to this action. Turning to the various allegations included in Plaintiffs EEOC charge, Complaint, and Opposition, as noted above, Plaintiff has abandoned his retaliation claim, which alleged that Plaintiff was terminated because he complained when Mr. Wyatt refused to schedule Plaintiffs lunch breaks so as to allow him to attend Friday prayer sessions. Nevertheless, in his Opposition, Plaintiff appears to attempt to recast those allegations into an independent claim that Defendant failed to accommodate his religious practice. See Pl.’s Opp’n at 5, 9-12. Defendant argues that Plaintiff cannot pursue such a claim because he did not separately plead it in his Complaint, and further argues that any failure to accommodate claim is untimely because Plaintiff did not file an EEOC charge of failure to accommodate within 300 days of “the alleged unlawful employment practice.” See Def.’s Reply at 9-10. Defendant’s first argument fails because Plaintiffs January 4, 2006 EEOC charge alleges that he “was unjustifiably denied a reasonable accommodation (i.e., the opportunity to use [his] lunch break for [his] ‘Friday Muslim Prayer’ session from 1:10 p.m. to 2:10 p.m.) with respect to [his] religion on numerous occasions.” See Def.’s Ex. 35 (1/4/06 EEOC Charge). The Court therefore concludes that Plaintiffs failure to accommodate claim is not barred, even though not separately pled in his Complaint, because it “could have reasonably been expected to grow out of [his] earlier complaint,” and is “like or related” to the claims of discrimination raised in his EEOC charge. See Wiley v. Glassman, 511 F.3d 151, 160 (D.C.Cir.2007) (quoting Weber v. Battista, 494 F.3d 179, 184 (D.C.Cir.2007)). It is less dear whether Plaintiffs failure to accommodate claim is, as Defendant argues, time barred because Plaintiff did not file an EEOC charge until January 4, 2006. Defendant appears to be correct that a rejection of a request for an accommodation is a “discrete act of discrimination” that triggers Title VII’s statutory charge-filing requirement, and not a “continuing violation.” See Mayers v. Laborers’ Health & Safety Fund of N. Am., 478 F.3d 364, 368-69 (D.C.Cir.2007) (because failure to accommodate disability is a discrete act, plaintiffs complaint was timely only as to acts that occurred within 180 days of her EEOC charge); see also Elmenayer v. ABF Freight Sys., Inc., 318 F.3d 130, 134-35 (2d Cir.2003) (“an employer’s rejection of an employee’s proposed accommodation for religious practices does not give rise to a continuing violation”). Nevertheless, Plaintiffs EEOC charge suggests that his request for a religious accommodation was denied as late as August 2005. Def.’s Ex. 35 (1/4/06 EEOC Charge) (stating that Plaintiffs request to attend Friday prayer sessions was denied “[f]rom approximately 2/00 to 8/05.”). As such, Plaintiff may have raised his failure to accommodate claim within 180 days, and well within 300 days, of the alleged unlawful employment practice. The Court need not determine whether Plaintiffs failure to accommodate claim is time barred, however, because Plaintiff cannot state a prima facie accommodation claim and therefore cannot pursue an independent claim on that basis. To state a prima facie claim, Plaintiff must show that “(1) [he] held a bona fide religious belief conflicting with an employment requirement; (2) [he] informed [his] employers of [his] belief; and (3) [he was] disciplined for failure to comply with the conflicting employment requirement.” Lemmons v. Georgetown Univ. Hosp., 431 F.Supp.2d 76, 95 (D.D.C.2006) (citing cases from other circuits); see also Taub v. FDIC, No. 96-5139, 1997 WL 195521, at *1 (D.C.Cir. Mar. 31, 1997). If the plaintiff successfully establishes aprima facie case, “the burden shifts to the employer to show that it was unable reasonably to accommodate the plaintiffs religious needs without undue hardship.” Lemmons, 431 F.Supp.2d at 95. Here, there is no dispute that Plaintiff meets the first and second prongs. As to the third, however, Plaintiff does not allege that he chose to attend Friday prayers in lieu of driving an assigned route, and therefore cannot — and does not — show that he was either disciplined or threatened with discipline as a result of the conflict between his religious belief and his employment requirements. Instead, Plaintiff asserts that Defendant “did not accommodate my religious observance request to pray during lunches; or they made it so hard that I was not able to do it.” Pl.’s Opp’n at 5. As the United States District Court for the Eastern District of Michigan aptly explained in a case where the plaintiff alleged that her employer failed to accommodate her Sabbath observance, “[b]y agreeing to work on her Sabbath, whether willingly or reluctantly, Plaintiff avoided suffering any adverse employment consequences as a result of her religious beliefs; rather her personal religious observance suffered on account of her adherence to her work schedule. Yet Title VII protects only the former, employment-related interests from abridgement.” Stone v. West, 133 F.Supp.2d 972, 985 (E.D.Mich.2001) (emphasis in original) (citation omitted); see also Thompson v. Kaufman’s Bakery, Inc., No. 03-CV-340S, 2005 WL 643433, at *2 (W.D.N.Y. Mar. 16, 2005) (same). Plaintiffs failure to establish the third prong of his prima facie case is fatal to an independent claim that Defendant failed to accommodate Plaintiffs request to schedule his lunch breaks around Friday prayer sessions. Nevertheless, the Court notes that Plaintiffs allegations of failure to accommodate may be probative of a discriminatory animus with respect to his wrongful termination claim. As such, the Court considers those allegations, as appropriate, in determining whether Plaintiffs wrongful termination claim survives Defendant’s motion for summary judgment. B. Plaintiffs Wrongful Termination Claim 1. Proper Standards Pursuant to Title VII, it is unlawful for an employer “to discharge any individual ... because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(l). To prove a violation of Title VII, Plaintiff must demonstrate by a preponderance of the evidence that the actions taken by the employer were “more likely than not based on the consideration of impermissible factors” such as race, ethnicity, or national origin. Tex. Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248, 254, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981) (internal quotation marks and citation omitted). In so doing, “the plaintiff may prove his claim with direct evidence, and absent direct evidence, he may indirectly prove discrimination” under the burden-shifting analysis created by McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). Brady v. Livingood, 456 F.Supp.2d 1, 6 (D.D.C.2006). “While courts have not precisely defined what constitutes ‘direct evidence,’ it is clear that ‘at a minimum, direct evidence does not include stray remarks in the workplace, particularly those made by nondecisionmakers or statements made by decision-makers unrelated to the decisional process itself.’ ” Brady, 456 F.Supp.2d at 6 (citing Ayala-Gerena v. Bristol Myers-Squibb Co., 95 F.3d 86, 96 (1st Cir.1996) (citing Price Waterhouse v. Hopkins, 490 U.S. 228, 251-52, 109 S.Ct. 1775, 104 L.Ed.2d 268 (1989) (plurality op.), superseded in part by The Civil Rights Act of 1991; Price Waterhouse, 490 U.S. at 277-78, 109 S.Ct. 1775 (O’Connor, J., concurring))). Although they may be probative of discrimination, “stray remarks do not satisfy a plaintiffs burden of proving discrimination by direct evidence.” Brady, 456 F.Supp.2d at 6 (citing Ayala-Gerena, 95 F.3d at 96 (citing Price Waterhouse, 490 U.S. at 277-78, 109 S.Ct. 1775 (O’Connor, J., concurring))). In the instant case, pro se Plaintiff alleges that Mr. Wyatt made various purportedly anti-Muslim and anti-Somalian comments, but does not clarify whether he believes these alleged comments constitute direct evidence of discrimination. The Court therefore clarifies that they do not. Although, as discussed below, Mr. Wyatt was intimately involved in the decisions to discipline and terminate Plaintiff, Plaintiff proffers no evidence whatsoever that any of Mr. Wyatt’s alleged comments were in any way related to those decisions. Mr. Wyatt’s alleged comments therefore appear to be “stray remarks,” which might be probative of discrimination, but are not sufficient as direct evidence of discrimination. See Price Waterhouse, 490 U.S. at 277-78, 109 S.Ct. 1775 (O’Connor, J., concurring). In the absence of direct evidence, it is necessary to apply the McDonnell Douglas tripartite burden-shifting framework to Plaintiffs discrimination claim. Cones v. Shalala, 199 F.3d 512, 516 (D.C.Cir.2000) (citing McDonnell Douglas, 411 U.S. at 802, 93 S.Ct. 1817). It is the district court’s responsibility to closely adhere to this analysis and go no further, as it does not sit as a “super-personnel department that reexamines an entity’s business decisions.” Fischbach v. D.C. Dep’t of Corr., 86 F.3d 1180, 1183 (D.C.Cir.1996) (internal citation and quotation marks omitted). Under the McDonnell Douglas paradigm, Plaintiff has the initial burden of proving by a preponderance of the evidence a prima facie case of discrimination. McDonnell Douglas, 411 U.S. at 802, 93 S.Ct. 1817. If he succeeds, the burden shifts to Defendant to articulate some legitimate, non-discriminatory reason for Plaintiffs termination, and to produce credible evidence supporting its claim. Id. Defendant’s burden is only one of production, and it “need not persuade the court that it was actually motivated by the proffered reasons.” Burdine, 450 U.S. at 254, 101 S.Ct. 1089; see also St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 509, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993) (“[T]he determination that a defendant has met its burden of production (and has thus rebutted any legal presumption of intentional discrimination) can involve no credibility assessment.”). As such, while “the McDonnell Douglas framework shifts intermediate evidentiary burdens between the parties, [t]he ultimate burden of persuading the trier of fact that the defendant intentionally discriminated against the plaintiff remains at all times with the plaintiff.” Morgan v. Fed. Home Loan Mortgage Corp., 328 F.3d 647, 651 (D.C.Cir.2003), cert. denied, 540 U.S. 881, 124 S.Ct. 325, 157 L.Ed.2d 146 (2003); see also Burdine, 450 U.S. at 253, 101 S.Ct. 1089. If Defendant is successful, “the McDonnell Douglas framework — with its presumptions and burdens — disappears], and the sole remaining issue [is] discrimination vel non.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 142-43, 120 S.Ct. 2097, 147 L.Ed.2d 105 (2000) (internal citations and quotation marks omitted). At that point, Plaintiff has the burden of persuasion to show that Defendant’s proffered reason was not the true reason for the employment decision. Burdine, 450 U.S. at 256, 101 S.Ct. 1089. Pretext may be established “directly by persuading the court that a discriminatory reason more likely motivated the employer or indirectly by showing that the employer’s proffered explanation is unworthy of credence.” Id. at 256, 101 S.Ct. 1089; see also Reeves, 530 U.S. at 143, 120 S.Ct. 2097. “Proof that the defendant’s explanation is unworthy of credence is simply one form of circumstantial evidence that is probative of intentional discrimination, and it may be quite persuasive.” Reeves, 530 U.S. at 147, 120 S.Ct. 2097 (citing St. Mary’s Honor Ctr., 509 U.S. at 517, 113 S.Ct. 2742) (“[P]roving the employer’s reason false becomes part of (and often considerably assists) the greater enterprise of proving that the real reason was intentional discrimination.”); see also Aka v. Washington Hosp. Ctr., 156 F.3d 1284, 1290 (D.C.Cir.1998) (en banc) (“[A] plaintiffs discrediting of an employer’s stated reason for its employment decision is entitled to considerable weight.”). Notably, the Supreme Court has taken care to instruct trial courts that “a plaintiffs prima facie case, combined with sufficient evidence to find that the employer’s justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated.” Reeves, 530 U.S. at 148, 120 S.Ct. 2097. The Court of Appeals for the District of Columbia Circuit has distilled this analysis, noting that the fact-finder can infer discrimination from the combination of: (1) the plaintiffs prima facie case; (2) any evidence the plaintiff presents to attack the employer’s proffered explanation for its actions; and (3) any further evidence of discrimination that may be available to the plaintiff (such as independent evidence of discriminatory statements or attitudes on the part of the employer) or any contrary evidence that may be available to the employer (such as evidence of a strong record in equal opportunity employment). Aka, 156 F.3d at 1289. However, evidence in each of the three categories is not required. Id. “At this stage, if [plaintiff] is unable to adduce evidence that could allow a reasonable trier of fact to conclude that [defendant’s] proffered reason was a pretext for discrimination, summary judgment must be entered against [plaintiff].” Paquin v. Fed. Nat'l Mortgage Ass’n, 119 F.3d 23, 27-28 (D.C.Cir.1997). “[T]he court must consider all the evidence in its full context in deciding whether the plaintiff has met his burden of showing that a reasonable [fact-finder] could conclude that he has suffered discrimination.” Aka, 156 F.3d at 1290. 2. Application of the McDonnell Douglas Analysis a. Plaintiff’s Prima Facie Case At the outset, the Court notes that Defendant has already articulated a legitimate non-discriminatory reason for Plaintiffs termination, in both Mr. Wyatt’s September 16, 2005 memorandum notifying Plaintiff of his termination, see Def.’s Ex. 17 (9/16/05 Mem. from K. Wyatt to M. Isse), and the Hearing Panel’s November 28, 2005 memorandum affirming Plaintiffs termination, see Def.’s Ex. 32 (11/28/05 Mem. from M. Mikkelsen to I. Broder). As the D.C. Circuit recently reiterated in Czekalski v. Peters, 475 F.3d 360, 364 (D.C.Cir.2007), “once a defendant has proffered such a nondiscriminatory explanation, it has ‘done everything that would be required of [it] if the plaintiff had properly made out a prima facie case.’ ” Id. (quoting U.S. Postal Serv. Bd. of Governors v. Aikens, 460 U.S. 711, 715, 103 S.Ct. 1478, 75 L.Ed.2d 403 (1983)). Thus, whether Plaintiff actually made out a prima facie case “ ‘is no longer relevant,’ and the only question is ‘whether the defendant intentionally discriminated against the plaintiff.’ ” Id. Nevertheless, the Court evaluates Plaintiffs prima facie case because, as noted above, it “ ‘is part of the evidence [the Court] must consider in addressing the question’ of whether [Plaintiff] has created a genuine issue of [religious or national origin] discrimination.” Id. (quoting George v. Leavitt, 407 F.3d 405, 413 (D.C.Cir.2005)). Here, Plaintiff claims disparate treatment discrimination, and thus makes out a prima facie case “ ‘by establishing that: (1) [he] is a member of a protected class; (2) [he] suffered an adverse employment action; and (3) the unfavorable action gives rise to an inference of discrimination.’ ” Id. (quoting George, 407 F.3d at 412); see also Stella v. Mineta, 284 F.3d 135, 145 (D.C.Cir.2002). Defendant does not challenge Plaintiffs ability to establish his prima facie case, and the Court agrees that Plaintiff easily establishes each prong, with respect to both religious and national origin discrimination. As to the first two, it is undisputed that Plaintiff is a Muslim and a native of Somalia, and that his employment with the University was terminated. In establishing the third prong, Plaintiff may either “demonstrat[e] that [he] was treated