Peter Vrinceanu v. King County, Washington, et al.

Whether exclusion of non-minority/white employees from employer-sponsored training or wellness programming—here, a “BIPOC-only” session—constitutes unlawful reverse discrimination and racial segregation under Title VII § 703(a)(2) and 42 U.S.C. § 2000e-2(d); and whether such exclusion, defended as a form of “separate but equal” programming, violates the principles articulated in Brown v. Board of Education, thereby rendering the exclusion an actionable adverse employment action.1

Whether qualified immunity should be addressed where public officials received explicit written notice of alleged violations before the employment separation; and whether declining to reach qualified immunity conflicts with this Court’s precedent requiring analysis when officials are alleged to have violated clearly established law.2

Whether an employer may lawfully require employees, as a condition of continued employment, to (a) waive their right to pursue lawsuits, (b) waive their right to pending public records disclosures, and (c) falsely agree that they have received requested records when in fact they have not - and whether such compelled waivers and misrepresentations constitute unlawful retaliation, obstruction of statutory rights, and a violation of public policy under Title VII and 42 U.S.C. § 1983.3 'Brown v. Board of Education, 347 U.S. 483, 495 (1954) (“Separate educational facilities are inherently unequal.”); Title VII § 703(a)(2), 42 U.S.C. § 2000e-2(d); see Vasquez v. County of Los Angeles, 349 F.3d 634, 640 n.5 (9th Cir. 2003) (discussing adverse employment action requirement). 2 Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982) (qualified immunity protects officials unless they violate clearly established law). 3 King County Memorandum of Agreement (2025) (requiring waiver of statutory claims, including Title VII and WLAD, as condition of reinstatement). 4. Whether the lower courts erred by dismissing a later-filed action as duplicative rather than consolidating related cases under Fed. R. Civ. P. 42(a); by denying leave to amend based on Rule 8(a) purported futility without permitting a curative amendment; and by declining to adjudicate qualified immunity and other merits issues, where overlapping facts coexisted with distinct parties and claims.4 4 Adams v. Cal. Dep’t of Health Servs., 487 F.3d 684, 688-89 (9th Cir. 2007), abrogated in part by Taylor v. Sturgell, 553 U.S. 880 (2008) (standards for duplicative actions); Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034, 1041 (9th Cir.

(leave to amend and futility); Fed. R. Civ. P. 42(a).