Foster v. Univ. of Maryland Eastern

Plaintiff filed suit against the University under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., for discriminatory termination based on gender, retaliatory termination, and the creation of a hostile work environment. At issue was the effect of the Supreme Court’s decision in University of Texas Southwestern Medical Center v.Nassar on what Title VII retaliation plaintiffs must show to survive a motion for summary judgment. The court concluded that the McDonnell Douglas framework, which already incorporates a but for causation analysis, provides the appropriate standard for reviewing plaintiff’s claim. Applying this framework, the court found that summary judgment in favor of the University is not warranted on plaintiff's retaliation claim where a reasonable jury could conclude from plaintiff's evidence that the University's proffered justifications were not its real reasons for firing her and that the University's actual reason for firing her was to retaliate against her complaining about sexual harassment and for her subsequent complaints of ongoing retaliation. Therefore, the court reversed the district court's grant of summary judgment as to plaintiff's retaliation claim. The court affirmed the district court's grant of summary judgment on plaintiff's gender-based discrimination claim and hostile work environment claim. View "Foster v. Univ. of Maryland Eastern" on Justia Law