Gentleman v. State Univ. of New York, 21-1102-cv

Dr. Molly Gentleman was a SUNY Stony Brook faculty member on a three-year term (Sept. 2012–Aug. 2015); SUNY Stony Brook decided not to renew her contract in 2014.
Gentleman alleged she has bipolar disorder and brought claims under Section 504 of the Rehabilitation Act and 42 U.S.C. § 1983 (procedural due process) challenging the nonrenewal.
Substantial student complaints documented alleged verbal abuse, bullying, humiliation, poor evaluations, and mass course withdrawals; department chair held a student meeting on Oct. 29, 2014 and two weeks later notified Gentleman of nonrenewal (Nov. 14, 2014).
District court dismissed the § 1983 procedural due process claim (12(b)(6)) and later granted summary judgment for SUNY Stony Brook on the Rehabilitation Act claim; parties appealed.
On appeal the Second Circuit affirmed: it rejected the due process claim because an Article 78 proceeding was an adequate post-deprivation remedy that Gentleman never alleged was unavailable or that she pursued; it affirmed summary judgment on the Rehabilitation Act claim because the university produced a legitimate, nondiscriminatory reason (student complaints) and no reasonable jury could find but-for disability causation or pretext.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether procedural due process claim under § 1983 survives dismissal	Gentleman: nonrenewal deprived her of property without process—she was not allowed to "face her accusers" and timing impeded faculty challenge	SUNY: any random/unauthorized deprivation is remedied by New York Article 78; Article 78 is an adequate post-deprivation remedy, so § 1983 relief is barred	Affirmed dismissal: Article 78 was an adequate post-deprivation remedy and Gentleman did not allege it was unavailable or that she pursued it
Whether Rehabilitation Act claim survives summary judgment (disability discrimination)	Gentleman: nonrenewal was based on her bipolar disorder; colleagues’ perceptions and actions ("cat’s paw") caused the decision	SUNY: nonrenewal based on documented student complaints of abusive/bullying conduct and poor performance — legitimate, nondiscriminatory reason; no evidence of but-for disability causation	Affirmed summary judgment: employer showed a legitimate reason and no reasonable juror could find pretext or that disability was the but‑for cause

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions in complaints not assumed true)
Hudson v. Palmer, 468 U.S. 517 (random, unauthorized deprivations remedied by state post-deprivation remedies)
Hellenic Am. Neighborhood Action Comm. v. City of New York, 101 F.3d 877 (Article 78 as adequate post-deprivation remedy under § 1983)
Giglio v. Dunn, 732 F.2d 1133 (employee not deprived of due process for failing to pursue available Article 78 relief)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Natofsky v. City of New York, 921 F.3d 337 (but-for causation required for ADA/Rehabilitation Act employment claims)
Vasquez v. Express Ambulance Serv., Inc., 835 F.3d 267 ("cat’s paw" theory — supervisor as conduit of subordinate prejudice)
McPherson v. N.Y.C. Dep’t of Educ., 457 F.3d 211 (in discrimination cases courts evaluate what motivated employer, not truth of underlying allegations)
Davis v. N.Y.C. Dep’t of Educ., 804 F.3d 231 (elements of prima facie ADA/Rehabilitation Act employment claim)