751 F.Supp.3d 67
E.D.N.Y.2024Background
- Plaintiff Luigi Bonaffini, an Italian-born tenured professor at Brooklyn College, taught in the Italian Program of the Modern Languages and Literatures (MLL) Department.
- The Italian Program was put on hiatus in 2019 after consistently low enrollment for a decade and cancellation of numerous Italian courses due to lack of student interest.
- As a result, Bonaffini and other Italian faculty were reassigned, with Bonaffini specifically being asked to teach courses in the English Department (Western Civilization) rather than Italian-focused classes.
- Bonaffini alleged that this decision was motivated by national origin and age discrimination, as other programs with comparable enrollment were not suspended.
- The case comes before the District Court on defendants' motion for summary judgment on claims under Title VII and New York law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| National Origin Discrimination: | Suspension was motivated by bias against Italians; | Hiatus due to enrollment; plaintiff not singled out; legitimate | No inference of discrimination; summary judgment granted. |
| Suspension of Italian Program | other programs in similar shape not suspended. | non-discriminatory reasons. | |
| Adverse Employment Action | Reassignment and schedule changes were harmful. | Changes were minor/trivial; courses assigned were in Bonaffini's | Not adverse under new Muldrow standard or are de minimis. |
| capacity/expertise; five-hour schedule gap trivial. | |||
| Pretext for Discrimination | Alleged historical bias, comments by Provost, | Enrollment numbers and program viability justified the action; | No evidence of pretext; summary judgment granted. |
| and prior discrimination lawsuits. | program not being uniquely targeted. | ||
| Supplemental Jurisdiction over State Claims | Court should retain state law claims. | Federal claims dismissed, state claims distinct under state law. | Declined to exercise; state claims dismissed without prejudice. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for employment discrimination claims)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (sets summary judgment standard: no genuine dispute of material fact)
- Reeves v. Sanderson Plumbing Prods. Inc., 530 U.S. 133 (addresses pretext analysis under McDonnell Douglas)
- Univ. of Penn. v. EEOC, 493 U.S. 182 (academic administration disputes are not for courts to resolve)