17-2437
3rd Cir.Mar 22, 2018Background
- Dowdell, an African-American male, applied in 2014 for a full-time English Generalist faculty position at Community College of Philadelphia requiring a Master’s or Ph.D. in English, Composition, or a “closely-related field” with at least 18 graduate credits in advanced study in language/literature/developmental English/reading.
- His application listed a B.A. in English and a Master of Science in “Screenwriting/Film”; the College later determined the degree was in “Film” and likely lacked the requisite 18 credits.
- Dowdell advanced through initial interview rounds; the English Dept. Chair initially recommended him before reviewing his transcript, but after transcript review Dr. Gay and Dr. Thompson concluded he lacked the required coursework and did not recommend hire.
- Dowdell sued for race and gender discrimination under Title VII and 42 U.S.C. § 1981 alleging failure to hire; the District Court granted summary judgment for the College, finding he failed to establish a prima facie case.
- The Third Circuit reviewed de novo and affirmed, holding Dowdell failed the second McDonnell Douglas prima facie element (qualification for the position). The court also agreed with the District Court’s additional analyses on the fourth element and pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dowdell was qualified for the English Generalist position (McDonnell Douglas second prong) | Dowdell pointed to prior part-time English teaching, a College poster labeling him “accomplished faculty,” inclusion in an accreditation report, and the Dept. Chair’s pre-transcript statement that he appeared qualified | College argued the posted minimum required a Master’s/Ph.D. in English/Composition or closely-related field with ≥18 specific graduate credits, which Dowdell’s transcript did not show | Court held Dowdell failed to show he met the minimum educational qualifications (lacked 18 requisite graduate credits), so he did not establish a prima facie case |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (established burden-shifting framework for discrimination claims)
- Texas Dept. of Community Affairs v. Burdine, 450 U.S. 248 (plaintiff’s prima facie burden and allocation of proof in employment discrimination)
- Ezold v. Wolf, Block, Schorr & Solis-Cohen, 983 F.2d 509 (3d Cir.) (explains the required showing for being “sufficiently qualified”)
- Sarullo v. U.S. Postal Serv., 352 F.3d 789 (3d Cir.) (elements of prima facie failure-to-hire case)
- Castleberry v. STI Group, 863 F.3d 259 (3d Cir.) (applies McDonnell Douglas framework in § 1981/Title VII context)
- Faush v. Tuesday Morning, Inc., 808 F.3d 208 (3d Cir.) (standard of review for summary judgment)
- Burton v. Teleflex Inc., 707 F.3d 417 (3d Cir.) (summary judgment standard)