Morales-Cruz v. University of Puerto Rico, 676 F.3d 220

Morales-Cruz hired as adjunct professor (2002); promoted to tenure-track with five-year probation.
During probation, she and a male co-teacher led the Legal Aid Clinic; a student became pregnant due to the co-teacher’s liaison.
In 2008 Morales-Cruz requested a one-year extension before tenure review; Dean and committees evaluated the extension.
Personnel committee recommended extension (May 7, 2008) by two-to-one vote; dissenter criticized her handling of the student relationship.
Dean initially supported extension but later recommended denial after critical remarks in his dissent; he commented on her judgment.
Administrative committee denied the extension, effectively terminating her employment at probation’s end; Morales-Cruz filed Title VII charge and suit after EEOC right-to-sue letter.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discrimination based on gender-stereotyping plausibility	Morales-Cruz argues she was treated due to gender stereotypes.	Defendants contend no gender-based motive; remarks were gender-neutral.	Dismissed; no plausible gender-stereotyping claim.
Retaliation plausibility	Actions after complaint show retaliation for opposing discrimination.	No protected conduct shown; remarks were gender-neutral.	Dismissed; no plausible retaliation claim.

Price Waterhouse v. Hopkins, 490 U.S. 228 (1989) (gender stereotyping theory protection under Title VII)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
Twombly v. Bell Atl. Corp., 550 U.S. 544 (2007) (pleading must contain plausible facts, not mere recitals)
Fantini v. Salem State Coll., 557 F.3d 22 (1st Cir.2009) (requires good faith, reasonable belief in violation of law for retaliation claims)
Clark County Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (protected conduct required for retaliation claims)
Weinstock v. Columbia Univ., 224 F.3d 33 (2d Cir.2000) (remarks must be more than trivial or gender-neutral to support discrimination)