Allen-Noll, Taysheedra v. Madison Area Technical College, 3:18-cv-00216

Background

Plaintiff Taysheedra Allen‑Noll, an African American full‑time nursing instructor at Madison Area Technical College (MATC) from 2009–2014, alleges race discrimination, retaliation for complaining about race discrimination, hostile work environment, and violations of procedural due process after MATC declined to renew her contract.
From 2010–2013 MATC officials and multiple students repeatedly complained about Allen‑Noll’s teaching, classroom conduct, grading timeliness, availability, and interactions with colleagues and clinical sites.
MATC placed Allen‑Noll on three sequential Performance Improvement Plans (PIPs) (May 2012, Dec. 2012, Dec. 2013) documenting persistent deficiencies and offering supervision and remedial support; Allen‑Noll disputes improvement but produced little admissible evidence to that effect.
Allen‑Noll filed internal discrimination/harassment complaints (May 2011; Dec. 2013) and two ERD complaints (Dec. 2013; July 2014) asserting race‑based mistreatment and later alleging the nonrenewal was retaliatory.
The MATC board, after a private conference as required by Wisconsin law, voted 6–2 to non‑renew Allen‑Noll’s contract in May 2014; she does not identify biased board members or direct racial slurs in the record.
The district court accepted most defendants’ proposed facts as undisputed due to plaintiff’s failure to properly respond to proposed findings and granted summary judgment for defendants, concluding plaintiff failed to present evidence creating a triable issue on causation or a protected property interest.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race discrimination under Title VII / § 1981	Allen‑Noll contends colleagues and supervisors targeted her (PIPs, removal from clinical site, soliciting negative student comments) because she is African American	Defendants point to extensive, documented student and faculty complaints and legitimate nondiscriminatory reasons for monitoring, PIPs, and nonrenewal; no evidence of racial animus	Granted for defendants — no admissible evidence that race caused adverse actions
Retaliation for complaining about race discrimination	Allen‑Noll says she was disciplined and non‑renewed after complaining internally and to ERD	Defendants show complaints were investigated; PIPs predated or were justified by documented performance issues; timing and evidence insufficient to show but‑for causation	Granted for defendants — plaintiff failed to show causal link
Hostile work environment / harassment	Plaintiff alleges ongoing harassment by supervisor/colleagues based on race	Defendants note absence of racial slurs, pervasive race‑based conduct, or evidence tying conduct to race; disputes concern performance and conduct	Granted for defendants — plaintiff did not brief or present evidence to sustain claim
Procedural due process (property interest in employment)	Allen‑Noll argues board could only non‑renew non‑probationary faculty for cause and PIP requirement created property interest	Defendants and record show no contractual/tenure provision limiting nonrenewal; Wisconsin statute prescribes process but not substantive protection	Granted for defendants — no constitutionally protected property interest shown

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (establishes summary judgment burden framework)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden‑shifting framework for discrimination claims)
Skiba v. Illinois Central Railroad Co., 884 F.3d 708 (standard for proving discrimination at summary judgment)
Ortiz v. Werner Enterprises, Inc., 834 F.3d 760 (evaluate all evidence; causation inquiry)
Burton v. Bd. of Regents of Univ. of Wis. Sys., 851 F.3d 690 (retaliation requires but‑for causation)
Beischel v. Stone Bank Sch. Dist., 362 F.3d 430 (Wisconsin dismissal procedures did not create property interest)
Perry v. Sindermann, 408 U.S. 593 (no property interest absent tenure/contract limiting dismissal)
Kodl v. Bd. of Educ. Sch. Dist. 45, Villa Park, 490 F.3d 558 (temporal proximity alone rarely creates triable issue on causation)