Appeals court revives ex-DOE economist Farah Naz discrimination claims

A federal appeals court revived the core discrimination claims of former Department of Energy economist Farah Naz, saying the district court moved too quickly when it threw out her case at the pleading stage. The ruling leaves her retaliation claim dismissed, but sends back race, gender, sex, religion and national-origin allegations that the court said deserved a fuller look.

Naz, described by the court as a Muslim woman of Pakistani origin, worked from January 2017 through January 2021 in the Department of Energy’s Office of Energy Consumption and Efficiency Analysis, a unit that projects industrial-energy-consumption trends and publishes analyses in DOE publications. Her lawsuit, filed in the U.S. District Court for the District of Columbia on June 16, 2022, said she was discriminated against and retaliated against in a series of workplace actions that ended in her firing.

The district court dismissed the case on September 30, 2023, but the D.C. Circuit, in an opinion issued June 9, 2026 in No. 23-5237, concluded that dismissal was too sweeping. The appellate court affirmed dismissal of the retaliation claim, but vacated the ruling on the discrimination claims and remanded the case for further proceedings. Chris Wright, the current secretary of the Department of Energy, was the appellee.

What mattered most to the panel was procedure. Under D.C. Circuit precedent, judges generally must look beyond the complaint when deciding whether a self-represented plaintiff has stated a claim. The court said the district judge appears to have overlooked a potentially decisive allegation in Naz’s opposition to the government’s motion to dismiss, a filing that could change the legal analysis. A companion summary of the case says that allegation involved a supervisor rejecting a Ramadan accommodation request while making a remark Naz says reflected anti-Muslim bias.

That distinction matters beyond this DOE dispute. Naz remains without a final merits ruling, but the appellate court’s decision gives her a path to try to prove that the treatment she described amounted to unlawful discrimination. For federal employees and applicants bringing Title VII cases against agencies, the opinion is a reminder that courts cannot treat a pro se complaint as the only place where the facts appear.

The oral-argument record also adds context. Naz had worked at the Commerce Department for nearly 17 years before joining DOE, testified in October 2017 in support of a colleague’s Equal Employment Opportunity complaint alleging race discrimination, and said her relationship with her supervisor worsened after that testimony. She also said she received positive performance reviews for roughly 18 months after joining DOE before the workplace climate changed. Anthony F. Shelley appeared as court-appointed amicus curiae supporting Naz during the January 16, 2025 argument, underscoring how closely the court viewed the case’s procedural stakes.