Ceglia v. Youngstown State Univ.
2016 Ohio 7235
| Ohio Ct. Cl. | 2016Background
- Plaintiff Nickola Ceglia, a 58‑year‑old LISW‑S with extensive adjunct teaching history at Youngstown State University (YSU), applied for a full‑time instructor/assistant professor social work position posted Nov. 7, 2012.
- Nineteen applicants applied; a faculty search committee shortlisted six (including Ceglia) and ultimately invited three for on‑campus interviews: Madry, Holcomb‑Hathy, and Woods. Madry declined; Holcomb‑Hathy accepted the offer.
- Committee members reviewed applications, contacted references using a standard question list, and completed evaluation grids. Reference comments and prior teaching performance influenced rankings.
- Reported negative evaluative points about Ceglia included a reference remark that he was “not the best at paperwork” and complaints by a faculty member (Wyant) that students from his 2010 Research Methods course were underprepared for subsequent coursework.
- Ceglia alleged age discrimination (R.C. 4112.02), arguing he was passed over because he was older and that Holcomb‑Hathy did not meet the minimum teaching qualification; YSU defended on nondiscriminatory grounds based on references, teaching concerns, and Holcomb‑Hathy’s acceptable qualifications and regional contacts.
- The magistrate found Ceglia established a prima facie age‑discrimination case but held YSU produced legitimate, nondiscriminatory reasons; Ceglia failed to show those reasons were pretextual. Judgment recommended for defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie age discrimination | Ceglia (58) was qualified, suffered adverse action (not interviewed/ not hired), and a substantially younger applicant (Holcomb‑Hathy, 44) was selected | YSU did not dispute elements but argued nondiscriminatory reasons explained decision | Prima facie case found to be established |
| Legitimate nondiscriminatory reason for rejection | Ceglia contends committee reasons are pretextual | YSU cites negative reference comment about paperwork, complaints about his Research Methods teaching, and Holcomb‑Hathy’s strengths (organization, contacts) | YSU met burden to articulate legitimate, nondiscriminatory reasons |
| Pretext (whether employer reasons were false or masked age bias) | Ceglia argues reasons lack basis, are insufficient, and committee comments (“mid‑career”) show age animus | YSU argues reference notes and faculty complaints had factual basis; “mid‑career” comment not ageist; committee followed typical procedures | Ceglia failed to prove pretext or discriminatory animus; reasons found credible and sufficient |
| Minimum‑qualifications challenge to selected candidate | Ceglia argues Holcomb‑Hathy lacked required teaching experience at time of posting | YSU notes Holcomb‑Hathy began an adjunct YSU teaching role before applying and had relevant training/agency contacts; committee found her experience acceptable | Magistrate found Holcomb‑Hathy met minimum qualifications |
Key Cases Cited
- Plumbers & Steamfitters Joint Apprenticeship Commt. v. Ohio Civ. Rights Comm., 66 Ohio St.2d 192 (Ohio 1981) (federal Title VII case law is generally applicable to R.C. Chapter 4112 claims)
- Coryell v. Bank One Trust Co., N.A., 101 Ohio St.3d 175 (Ohio 2004) (elements of prima facie age‑discrimination case)
- Williams v. City of Akron, 107 Ohio St.3d 203 (Ohio 2005) (burden‑shifting framework and plaintiff’s opportunity to show pretext)
- Texas Dept. of Community Affairs v. Burdine, 450 U.S. 248 (U.S. 1981) (employer’s burden to proffer legitimate nondiscriminatory reason)
- St. Mary's Honor Center v. Hicks, 509 U.S. 502 (U.S. 1993) (plaintiff must show both falsity of employer reason and that discrimination was real reason)
- Dews v. A.B. Dick Co., 231 F.3d 1016 (6th Cir. 2000) (three‑part test for showing pretext)
- Johnson v. Kroger Co., 319 F.3d 858 (6th Cir. 2003) (proof required to permit factfinder to infer intentional discrimination)