Campbell v. Bristol Community College, 395 F.Supp.3d 175

Background

Campbell, an African-American probationary "Career Development Counselor" (Navigator), was hired Aug 20, 2012 under a federal grant (MACCWFDTA) and terminated Dec 26, 2012.
Staff repeatedly referred to the grant as the "Mack Daddy" program; Campbell objected, saying the term was offensive/linked to "pimp" or racial meaning; supervisors and HR were told of her complaints (including a Dec 17 meeting with HR).
During her ~4 months Campbell received multiple written and email performance warnings citing attendance, organization, documentation errors, missed meetings, and a reported October incident with a coworker.
The college says contemporaneous documentation justified termination; Campbell alleged the termination was discriminatory (race) and retaliatory (for complaining about the term).
MCAD and EEOC found lack of probable cause; Campbell sued in federal court alleging Title VII discrimination and retaliation. Court dismissed hostile-work-environment and state-law claims; summary judgment motion followed.
Court granted summary judgment on the race-discrimination claim but denied summary judgment as to Title VII retaliation (close temporal proximity and disputed causal motive created triable issue).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Campbell was fired because of race (Title VII discrimination)	Campbell says she was terminated due to race; was replaced by a white woman	BCC says termination resulted from documented poor performance and probationary status	Granted for defendant — plaintiff failed to show satisfactory job performance or pretext for racial animus
Whether Campbell engaged in protected activity by complaining about "Mack Daddy"	Complaints reflected a good-faith, reasonable belief that usage was racially offensive and violative of Title VII	BCC argues the term was not racially charged and complaints were objectively unreasonable	Court: complaint could be a protected activity — objective reasonableness not so lacking as to foreclose claim
Whether termination was an adverse action causally linked to protected activity (retaliation)	Temporal proximity (complaint Dec 17; termination ~Dec 26) and contemporaneous events show causal link	BCC points to independent, non-retaliatory performance-based reasons for firing	Denied summary judgment on retaliation — nine-day proximity plus factual disputes create genuine issue of material fact
Burden-shifting and pretext	Campbell argues BCC's proffered performance reasons were pretextual	BCC offered legitimate nondiscriminatory reasons; court must assess pretext at summary judgment	For discrimination claim, plaintiff failed to raise pretext. For retaliation, plaintiff raised sufficient factual dispute on motive to survive summary judgment

Key Cases Cited

Mesnick v. General Elec. Co., 950 F.2d 816 (1st Cir. 1991) (summary judgment role and burden)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination cases)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (nonmoving party must present affirmative evidence to create genuine issue)
Medina-Munoz v. R.J. Reynolds Tobacco Co., 896 F.2d 5 (1st Cir. 1990) (definition of genuine issue at summary judgment)
O’Connor v. Steeves, 994 F.2d 905 (1st Cir. 1993) (indulging inferences for nonmovant at summary judgment)
Collazo v. Bristol–Myers Squibb Mfg., Inc., 617 F.3d 39 (1st Cir. 2010) (elements and burden-shifting in Title VII retaliation claims)
Planadeball v. Wyndham Vacation Resorts, Inc., 793 F.3d 169 (1st Cir. 2015) (plaintiff need only raise genuine issue that retaliation motivated adverse action)
Dominguez-Cruz v. Suttle Caribe, Inc., 202 F.3d 424 (1st Cir. 2000) (standard for proving retaliatory motive)
Clark County School Dist. v. Breeden, 532 U.S. 268 (2001) (temporal proximity as evidence of causation)
Calero-Cerezo v. United States Dept. of Justice, 355 F.3d 6 (1st Cir. 2004) (month-long proximity may establish causal inference)