In fact, his replacement was another white male. A district court's decision to stay discovery is reviewed for abuse of discretion. In these circumstances, we conclude that the district court did not abuse its discretion by refusing to allow further discovery. Willoughby argues that the district court abused its discretion by not allowing him to add to his complaint claims based on Title VII of the Civil Rights Act of 1964 and on the District of Columbia Human Rights Act. The decision whether to allow a plaintiff to amend his complaint is also reviewed for abuse of discretion but leave to amend should be freely given unless there is a good reason, such as futility, to the contrary.
Futility provides a good reason here.
A claim under the District of Columbia Human Rights Act likewise would have been futile. Those claims must be brought within one year from the date the alleged violation occurs or is discovered. D.C. Code Ann. His original complaint gave no notice that he was claiming a violation of the Human Rights Act and he points to no new information or other evidence suggesting that he discovered the alleged violation after his termination. Furthermore, Willoughby's Human Rights Act claim suffers from the same substantive flaws as his Title VII claim.