Judge Dismisses Primus Race Bias Lawsuit
A federal judge threw out a former Surface Transportation Board chair's claim that his removal by the Trump administration was racially discriminatory.
Updated on Nov. 6, 2026 in Political Parties

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Federal Judge Dabney L. Friedrich of the U.S. District Court for the District of Columbia dismissed a race discrimination lawsuit filed by Robert Primus, a Black former government official removed from the Surface Transportation Board. Friedrich ruled that Primus's allegations did not support a plausible inference of discriminatory intent.
Why it matters
The ruling means Primus's claim that his removal was racially motivated will not proceed in court under the current pleadings. It also shows how difficult it can be for former officials to prove discriminatory intent when they are removed during a change in administration.
The dismissal was issued by a single federal district judge after reviewing the complaint's allegations. Primus was one of two Democrats on the Surface Transportation Board at the time of his removal, and whether he will appeal the ruling remains unclear.
The players
Robert Primus
Robert Primus is a Black former government official who chaired the Surface Transportation Board until his removal in 2025.
Dabney L. Friedrich
Dabney L. Friedrich is a federal judge on the U.S. District Court for the District of Columbia who presided over and dismissed the case.
The details
Primus, who was nominated to the Surface Transportation Board by Trump in 2020, was removed as board chair when Trump returned to office in 2025. He alleged the removal was racially discriminatory, but Friedrich concluded his allegations failed to plausibly show discriminatory intent.
Timeline
2020: Trump nominates Primus to the Surface Transportation Board.
2025: Primus is removed as board chair when Trump returns to office.
Nov. 5, 2026: Judge Dabney L. Friedrich dismisses the lawsuit.
Big Picture
The dismissal fits a broader pattern of contested personnel removals at independent federal agencies following the 2025 return of the Trump administration. Courts have so far required plaintiffs to show specific evidence of discriminatory intent in such cases.
The ruling means Primus cannot currently pursue his discrimination claim in federal court, which affects his ability to seek damages or reinstatement on that basis. Other former officials removed during leadership transitions may face similar hurdles when proving intent.
The takeaway
Proving discriminatory motive in a removal case requires specific factual allegations, not just the fact of removal and a protected status. Officials and advocates watching these disputes should track how courts weigh such claims.
Further reading
Explore more coverage in Political Parties for context on the partisan dynamics behind federal appointments.
Source note: This article includes information reported by Bloomberglaw.
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