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BELTZ v. THE UNIVERSITY OF PITTSBURGH
2:19-cv-01572
| W.D. Pa. | Dec 15, 2021
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Background

  • 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)
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Case Details

Case Name: BELTZ v. THE UNIVERSITY OF PITTSBURGH
Court Name: District Court, W.D. Pennsylvania
Date Published: Dec 15, 2021
Docket Number: 2:19-cv-01572
Court Abbreviation: W.D. Pa.