Charles Collins v. Jackson Public School District, 609 F. App'x 792

Collins, a former Callaway High School teacher/coach, filed a Title IX complaint in July 2009 alleging discrimination against female athletes; OCR opened an investigation in October 2009.
Collins alleges retaliatory acts after his involvement with the Title IX matter: (1) a negative evaluation by Assistant Principal Dr. Pamela Self, (2) HR Director Carol Dorsey’s failure to investigate his grievance, (3) transfer to the District’s Capital City Alternative School in August 2010, and (4) nonrenewal of his contract in April 2012.
Collins filed a retaliation complaint with OCR in June 2010; OCR closed that retaliation investigation in December 2010 for insufficient evidence.
Collins sued the District in April 2012 under Title IX (retaliation) and asserted several state-law tort claims; the District moved for summary judgment.
The district court granted summary judgment on the federal retaliation claims (finding failures as to causation, adverse action, and abandonment), and declined supplemental jurisdiction over the state-law claims, dismissing them without prejudice.
The Fifth Circuit affirmed: it found insufficient evidence of defendants’ knowledge (for two claims), no admissible evidence that the transfer was an objectively worse position plus insufficient temporal proximity, and abandonment of the nonrenewal claim; it affirmed dismissal of state-law claims without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether adverse acts were retaliatory based on evaluation (Self) and HR inaction (Dorsey)	Self and Dorsey acted in retaliation for Collins’ Title IX involvement	Neither Self nor Dorsey knew of Collins’s protected activity, so no causation	Dismissed — no evidence defendants knew of protected activity, so causation lacking
Whether transfer to Alternative School was an adverse employment action and causally connected	Transfer was a demotion (less prestigious/less opportunities) and thus adverse; temporally connected	Collins produced no record evidence showing the Alternative School was objectively worse and transfer occurred >9 months after protected activity	Dismissed — no admissible evidence the new post was objectively worse and temporal proximity too remote for causation
Whether nonrenewal of contract supports retaliation claim	Nonrenewal was retaliatory	District argued on merits; district court found Collins did not brief the issue in response	Abandoned on appeal for failure to brief; dismissal affirmed
Whether district court should retain supplemental jurisdiction over state-law claims	Plaintiff sought resolution of state claims in federal court	Once federal claims were dismissed, court should decline supplemental jurisdiction	Affirmed — district court properly dismissed state-law claims without prejudice

Berquist v. Washington Mut. Bank, 500 F.3d 344 (5th Cir. 2007) (summary judgment reviewed de novo)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment standard and need for record evidence)
Willis v. Cleco Corp., 749 F.3d 314 (5th Cir. 2014) (elements of prima facie Title IX retaliation claim)
Lowrey v. Texas A&M Univ. Sys., 117 F.3d 242 (5th Cir. 1997) (Title IX/Title VII anti-retaliation language interpreted similarly)
Watts v. Kroger Co., 170 F.3d 505 (5th Cir. 1999) (defendant must know of protected activity for causation)
Breaux v. City of Garland, 205 F.3d 150 (5th Cir. 2000) (narrow view of adverse employment action)
Thompson v. City of Waco, Tex., 764 F.3d 500 (5th Cir. 2014) (transfer can be adverse if objectively worse)
Gorman v. Verizon Wireless Tex., L.L.C., 753 F.3d 165 (5th Cir. 2014) (temporal proximity must be very close for causation)
Price v. Digital Equip. Corp., 846 F.2d 1026 (5th Cir. 1988) (arguments not briefed are forfeited)
Certain Underwriters at Lloyd's, London v. Warrantech Corp., 461 F.3d 568 (5th Cir. 2006) (decline supplemental jurisdiction when federal claims are eliminated)