Mills v. Southern Connecticut State University, 519 F. App'x 73

Mills sued Southern Connecticut State University and two employees for Title VII and CFEPA discrimination, retaliation, and hostile work environment, plus a §1983 equal protection claim.
The district court granted summary judgment in favor of the University and individuals on all claims on August 11, 2011.
On appeal, Mills challenges the dismissal of her discrimination, hostile work environment, retaliation, CFEPA aiding-and-abetting, and equal protection claims.
The court reviews de novo, viewing the record in the light most favorable to Mills to determine if genuine disputes of material fact exist.
Only the denial of Mills’s promotion was found to be an adverse employment action for purposes of Title VII claims; other alleged incidents were not materially adverse.
The panel affirms the district court’s summary judgment on all claims, including hostile environment, retaliation, CFEPA, and equal protection.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discrimination prima facie and promotion denial	Mills claims gender discrimination based on failure to promote.	University showed no evidence of gender-based discriminatory intent or similarly situated comparators treated differently.	No genuine dispute; no inference of discrimination from promotion decision.
Hostile work environment	Hug, intimidating conduct, and shunning created a sex-based hostile environment.	Actions did not permeate the workplace or alter terms of employment because of gender.	Hostile environment claim fails as a matter of law.
Retaliation	Adverse actions followed protected activity and showed causal link to complaints.	No causal link shown between protected activity and adverse action; only promotion could count as adverse.	No triable issue; retaliation claim fails.
CFEPA aiding-and-abetting preservation	Aiding-and-abetting claim under CFEPA should survive.	No facts pleaded or evidence to support aiding-and-abetting.	Issue not preserved for appeal; no discussion.
Equal protection under §1983	Mills was treated more harshly than male colleagues.	Equal protection analysis mirrors Title VII; claim fails for similar reasons.	Equal protection claim fails.

Reynolds v. Barrett, 685 F.3d 193 (2d Cir. 2012) (prima facie discrimination framework under McDonnell Douglas)
Treglia v. Town of Manlius, 313 F.3d 713 (2d Cir. 2002) (adverse employment action includes failure to promote)
Mathirampuzha v. Potter, 548 F.3d 70 (2d Cir. 2008) (aggressive conduct alone not an adverse employment action)
Shumway v. United Parcel Serv., Inc., 118 F.3d 60 (2d Cir. 1997) (need for similarly situated treatment to show discrimination absent direct evidence)
Alfano v. Costello, 294 F.3d 365 (2d Cir. 2002) (sex-based hostile environment requires conduct due to sex)
Desardouin v. City of Rochester, 708 F.3d 102 (2d Cir. 2013) (hostile environment standard and evidence of impermissible discrimination)
Bucalo v. Shelter Island Union Free Sch. Dist., 691 F.3d 119 (2d Cir. 2012) (causal connection in discrimination/retaliation claims and timing)
Back v. Hastings on Hudson Union Free Sch. Dist., 365 F.3d 107 (2d Cir. 2004) (bias by non-decision-maker can taint promotion decisions)
Gorzynski v. JetBlue Airways Corp., 596 F.3d 93 (2d Cir. 2010) (temporal proximity can show causation in discrimination/retaliation claims)
Tepperwien v. Entergy Nuclear Operations, Inc., 663 F.3d 556 (2d Cir. 2011) (retaliation standards under Title VII)
Demoret v. Zegarelli, 451 F.3d 140 (2d Cir. 2006) (equality-based equal-protection analysis mirroring Title VII)
Desardouin v. City of Rochester, 708 F.3d 102 (2d Cir. 2013) (see above (duplicate entry to ensure completeness))