Carl Woods v. State of Washington

MEMORANDUM

1. Appellant Carl Woods appeals the district court’s grant of summary judgment dismissing his claims against his employer, the University of Washington (“University”), along with three co-workers and the State of Washington (collectively, “Defendants”), for discrimination and retaliation in violation of 42 U.S.C. § 1981 , Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq., and the Washington Law Against Discrimination, RCW 49.60 et seq. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

2. The district court did not abuse its discretion when it excluded evidence of the Defendants’ misconduct that predated Woods’ previous settlement with the University from being used as “context” for the instant claims. See Nat’l Steel Corp. v. Golden Eagle Ins. Co., 121 F.3d 496, 502 (9th Cir.1997). The settlement agreement stipulates that Woods “completely releases” the University and its agents “from any and all liability that they may have relating to Carl Woods’ employment with the University.” Because the agreement released all claims “relating to” events from Woods’ employment before the settlement, Woods is barred from relying on…