Imputing Improper Motive

“With regard to the letter, [Plaintiff]’s allegation is that he asked Chief Justice Jefferson to keep the letter confidential, not that Chief Justice Jefferson actually did so. In fact, [Defendant alleged that Chief Justice Jefferson did not answer the letter himself, establishing that the letter had not remained confidential. With regard to the disciplinary complaint,

“[Plaintiff was not required to allege how [Defendant] knew of the letter and complaint, only that [Defendant] knew. Having done so, he has sufficiently pleaded that his letter and his disciplinary complaint precipitated [Defendant]’s allegedly untoward conduct.” Anderson, 2016 WL 6647759, at *5 (footnotes omitted).

As discussed above, Hauss allegedly misrepresented the erratic test results—which Dr. McKinnon and Audiologist Sanders attribute to Brown’s hearing disability—to the decisionmaker Goodson, thereby creating a factual issue as to whether Hauss exhibited disability-based animus. In turn, Goodson conducted a subsequent investigation into Brown’s conduct, including, among other things, consultation with Hauss. Goodson testified