Holcomb v. State Univ. of N.Y. at Fredonia
698 F. App'x 30
| 2d Cir. | 2017Background
- Paula Holcomb, a SUNY Fredonia faculty member, alleged retaliation after filing a sexual-harassment complaint against department chair Karl Boelter.
- Following an inflammatory joint email by Holcomb and colleague David Rudge about a Concerto Competition, SUNY imposed nearly identical sanctions on both faculty members.
- Holcomb was later not reinstated to her prior position; she contends this was retaliation for her harassment complaint.
- Defendants (SUNY Fredonia and administrators) maintain the sanctions and non-reinstatement were non-retaliatory responses to the email incident and Holcomb’s refusal to participate in reconciliation steps.
- The district court granted summary judgment for defendants on Title VII, Title IX, §1983, and NYSHRL retaliation claims and declined supplemental jurisdiction over Holcomb’s NY Labor Law claims; the Second Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Holcomb’s harassment complaint was a motivating or but-for cause of sanctions after the Concerto Competition email | Holcomb: sanctions and non-reinstatement were retaliation for complaint against Boelter | Defendants: sanctions responded to the inflammatory email; Holcomb and Rudge were equally sanctioned for the same conduct | Court: Holcomb failed to show causation; sanctions were non-retaliatory; summary judgment for defendants affirmed |
| Whether defendants’ proffered reason for not reinstating Holcomb was pretextual | Holcomb: SUNY refused reconciliatory process and used complaint as cover for non-reinstatement | Defendants: offered evidence they were willing to mediate; Holcomb did not engage in mediation or reconciliation efforts | Court: Holcomb presented no evidence of pretext; defendants’ explanation stands |
| Whether Title VII/Title IX/§1983/NYSHRL retaliation claims are judged under the same framework and causation standard | Holcomb: (implicitly) argues retaliation standards should apply favorably to her | Defendants: apply McDonnell Douglas burden-shifting and require causation showing | Court: applied McDonnell Douglas; need not decide universally applicable causation standard because Holcomb fails under both substantial-motivating-factor and but-for standards |
| Whether the district court erred in declining supplemental jurisdiction over state NY Labor Law claims | Holcomb: sought to pursue NY Labor Law retaliation claims in district court | Defendants: district court discretion to decline supplemental jurisdiction | Held: appellate court affirmed the district court’s judgment (including its exercise of discretion regarding supplemental jurisdiction) |
Key Cases Cited
- Marvel Characters, Inc. v. Kirby, 726 F.3d 119 (2d Cir. 2013) (standard of review for summary judgment)
- Hicks v. Baines, 593 F.3d 159 (2d Cir. 2010) (analyzing retaliation claims under Title VII principles across related torts)
- Summa v. Hofstra Univ., 708 F.3d 115 (2d Cir. 2013) (Title VII and Title IX standards for retaliation claims)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination/retaliation)
- Papelino v. Albany Coll. of Pharmacy of Union Univ., 633 F.3d 81 (2d Cir. 2011) (applying McDonnell Douglas to Title IX retaliation claims)
- Delaney v. Bank of Am. Corp., 766 F.3d 163 (2d Cir. 2014) (courts should not act as super-personnel departments reviewing employer business decisions)
- Scaria v. Rubin, 117 F.3d 652 (2d Cir. 1997) (same principle regarding court deference to employer personnel decisions)