Abdurahman Haji v. Columbus City Schools, 621 F. App'x 309

Haji, a Somali imam hired in Nov. 2005 as an ESL instructional assistant at Mifflin Middle School, regularly left early on Fridays to lead mosque prayers; principal Lewis initially permitted these departures.
In late 2007 Haji posted a YouTube lecture criticizing the school for exposing Muslim students to Greek mythology; school officials learned of the video in early 2008 and investigated.
In Feb. 2008 Haji received a one-day suspension after complaints that he told parents to discipline students over filming and for confronting a teacher about hugging a female student.
In April 2008 the school rescinded Haji’s longstanding informal permission to leave on Fridays (after a supervisor complained his absences disrupted class) and instructed him to obtain prior permission or use leave.
Haji left without permission on April 25 and May 30; a June 5, 2008 disciplinary hearing recommended termination for neglect of duty, insubordination, and absence without leave; the Board ratified the termination on August 5, 2008.
Haji sued under 42 U.S.C. § 1983 (First Amendment retaliation) and Title VII (religious discrimination); the district court granted summary judgment to defendants; the Sixth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Haji established a prima facie First Amendment retaliation claim (protected speech caused termination)	Haji: video was protected speech; temporal proximity (video learned Mar 2008 → June 5 recommendation) and rescission of Friday-leave infer retaliatory motive	Defendants: actions were motivated by attendance violations and workplace disruption, not the video; termination was for insubordination and neglect of duty	Court: Prima facie established (temporal proximity + rescission). But defendants provided legitimate, non-retaliatory reasons (supervisor complaints, repeated unpaid departures) and would have terminated regardless — summary judgment for defendants.
Whether Haji established a prima facie Title VII religious-discrimination claim	Haji: treated because he is Muslim — disciplinary actions, investigation tone, and temporal sequence show discrimination	Defendants: discipline and investigation responded to conduct and classroom disruption; no comparator or additional evidence of discriminatory intent	Court: Haji failed to show comparator evidence or other evidence of discrimination; prima facie Title VII claim not made — summary judgment for defendants.

Dye v. Office of the Racing Comm’n, 702 F.3d 286 (6th Cir. 2012) (elements for First Amendment retaliation claim)
Bryson v. Regis Corp., 498 F.3d 561 (6th Cir. 2007) (temporal proximity can support causal inference)
Mickey v. Zeider Tool and Die Co., 516 F.3d 516 (6th Cir. 2008) (temporal proximity plus other evidence may establish causation)
Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (temporal proximity as evidence of causation)
Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (1977) (employer may avoid liability by proving it would have taken same action absent protected conduct)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for disparate-treatment prima facie case)
Tex. Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (1981) (prima facie burden and burden-shifting in discrimination cases)
Jenkins v. Rock Hill Local Sch. Dist., 513 F.3d 580 (6th Cir. 2008) (definition of adverse employment action in First Amendment context)
Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (Mt. Healthy burden-shifting in retaliation claims)
Connick v. Myers, 461 U.S. 138 (1983) (discipline for workplace conduct can be legitimate reason unrelated to protected speech)