Main v. Tulane University, 2:17-cv-01398

Sally Main, a long‑time Senior Curator at Tulane's Newcomb Art Gallery, alleged age (60) and disability (PTSD) discrimination and retaliation after Tulane eliminated her curator position effective July 30, 2015.
Tulane restructured the Gallery following an American Alliance of Museums (AAM) / MAP assessment recommending stronger academic credentials for the curator role; Tulane redefined the job and concluded Main did not meet the new scholarship/education requirements.
Main reported conflicts with the new Gallery Director, Dr. Monica Ramirez‑Montagut, during the ~4 months they worked together before Main took medical leave; Main sent a November 10, 2014 email referencing PTSD and requesting less hostile communications but did not file a formal accommodation request.
Ramirez‑Montagut responded by directing Main to Tulane’s Office of Disability Services; Main contacted Disability Services but requested no specific accommodation beyond a general desire for a less hostile workplace.
Tulane produced documentary evidence (AAM/MAP report and affidavits) showing the reorganization and new qualification standards predated Ramirez‑Montagut and were implemented for legitimate, non‑discriminatory reasons.
The district court granted Tulane’s motion for summary judgment, dismissing Main’s ADEA, ADA (discrimination and reasonable‑accommodation), retaliation, and related disclosure claims with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Age discrimination (ADEA) — termination	Main contends position elimination was motivated by age; Ramirez‑Montagut dislikes older people and tailored new job to exclude her.	Reorganization based on AAM/MAP recommendations; new curator required stronger academic/scholarly credentials which Main lacked.	Summary judgment for Tulane: no evidence Main's age was the but‑for cause of termination.
Disability discrimination (ADA) — termination	Main contends PTSD motivated adverse action.	Elimination was nondiscriminatory and based on objective AAM recommendations; no causal link to PTSD.	Summary judgment for Tulane: no evidence connecting termination to disability.
Reasonable accommodation (ADA)	Main treats Nov. 10, 2014 email as an accommodation request for PTSD.	Main never requested a specific accommodation; director properly referred her to Disability Services; Tulane gave leave requested.	Summary judgment for Tulane: no actionable accommodation request or denial.
Retaliation (ADA/related)	Nov. 10 email was protected activity; subsequent warning and later termination were retaliatory.	The warning was not an adverse action; termination months later resulted from reorganization, not retaliation; no causal proof.	Summary judgment for Tulane: no causal evidence; temporal proximity insufficient.

TIG Ins. Co. v. Sedgwick James, 276 F.3d 754 (5th Cir. 2002) (summary judgment standard and drawing inferences for nonmovant)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (standard for genuine issues of material fact at summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (party moving for summary judgment may show absence of evidence to support nonmovant)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for circumstantial discrimination claims)
Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009) (ADEA requires plaintiff prove age was the but‑for cause)
Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (2000) (prima facie case plus proof of pretext may permit inference of intentional discrimination)
EEOC v. LHC Group, Inc., 773 F.3d 688 (5th Cir. 2014) (ADA discrimination/summary judgment principles)