BELTZ v. THE UNIVERSITY OF PITTSBURGH
2:19-cv-01572
| W.D. Pa. | Dec 15, 2021Background
- Timothy Beltz, a white male strength & conditioning coach employed by the University of Pittsburgh for ~19 years, was terminated in June 2018 after the Women’s Basketball head coach was fired.
- Beltz worked with multiple teams, shared an office with Garry Christopher (a young Black Men’s strength coach), and had a long-running conflict with Christopher.
- Heather Lyke, the Athletic Director, undertook a staff overhaul after poor team performance and fired both Men’s and Women’s head coaches; some assistant/staff positions were eliminated or re-staffed.
- Christopher ultimately remained employed by the Athletic Department (and received professional-development support); Beltz did not get re-hired by the new Women’s coach and did not apply for the Men’s position.
- Beltz sued for race discrimination (Title VII, §1981), age discrimination (ADEA, PHRA), and Title IX retaliation; the University moved for summary judgment.
- The court denied summary judgment on the race- and age-discrimination claims (finding triable disputes on comparator/pretext), but granted summary judgment to the University on the Title IX retaliation claim (insufficient causation).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race discrimination (Title VII, §1981) | Beltz says Garry Christopher was a valid comparator (same job/role) who was treated more favorably, supporting an inference of racial discrimination and pretext. | Univ. says the men worked for different teams/coaches, had different employment conditions and independent hiring decisions, so Christopher is not a proper comparator. | Summary judgment denied as to race claims; a reasonable jury could find Christopher similarly situated and the Univ.’s reasons pretextual. |
| Age discrimination (ADEA, PHRA) | Beltz (46 at termination) alleges he was replaced by Rhen Vail, roughly 20 years younger, creating an inference of age discrimination. | Univ. contends legitimate non-discriminatory reason: program overhaul and new head coach discretion to select staff. | Summary judgment denied as to age claims; prima facie met and factual disputes (comments about energy, decision process) permit a jury to find pretext. |
| Title IX retaliation | Beltz contends his complaints about unfair treatment of the Women’s team were protected activity and caused his termination. | Univ. argues long temporal gap (~2 years) and no intervening pattern of antagonism; termination stemmed from coaching changes. | Summary judgment granted to Univ. on retaliation claim; plaintiff failed to show causation. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for disparate-treatment claims)
- Fuentes v. Perskie, 32 F.3d 759 (3d Cir. 1994) (standards for proving pretext at summary judgment)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (plaintiff retains ultimate burden of persuasion)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment requires no genuine issue of material fact)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (court must not weigh evidence or make credibility determinations at summary judgment)
- Sarullo v. U.S. Postal Service, 352 F.3d 789 (3d Cir. 2003) (existence of prima facie case is a question of law)
- Simpson v. Kay Jewelers, 142 F.3d 639 (3d Cir. 1998) (plaintiff’s burden to show similarly situated comparators)
- Young v. United Parcel Serv., 135 S. Ct. 1338 (2015) (prima facie burden is not onerous)
- Carvalho-Grevious v. Del. State Univ., 851 F.3d 249 (3d Cir. 2017) (retaliation prima facie elements and causation analysis)
- LeBoon v. Lancaster Jewish Cmty. Ctr. Ass’n, 503 F.3d 217 (3d Cir. 2007) (temporal proximity alone may be insufficient to show causation)
- Bray v. Marriott Hotels, 110 F.3d 986 (3d Cir. 1997) (inferences of pretext may arise from credibility gaps and inconsistent explanations)
