Stewart v. Morgan State University, 8:11-cv-03605

Background

Troy Stewart, an Ed.D. candidate at Morgan State University (a historically Black university), received two C grades and an "incomplete" in a spring 2010 semester and was dismissed from the program by November 2010 for failing to meet program academic standards.
Stewart contends he served a dual student/employee role during an internship (EDAD 603) supervised by Dr. Benjamin Welsh and alleges race discrimination and retaliation under Title VII, breach of contract, and § 1983 claims.
The internship included a signed "Statement of Agreement" outlining objectives; Stewart claims this created an employment contract and that his research would benefit Morgan State.
Morgan State maintains Stewart received no monetary compensation, the internship was academic credit (not employment), and dismissal resulted from academic review and program rules (program requires dismissal after two C’s).
After grade appeals and review by department faculty (including Chair Glenda Prime and internship instructor Warren Hayman), Stewart’s incomplete was changed to an F and dismissal was upheld. Stewart exhausted administrative remedies (EEOC right-to-sue).
The court granted summary judgment for defendants on all remaining claims and denied defendants’ motion to strike Stewart’s opposition (pro se filings accepted).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stewart was an "employee" under Title VII	Stewart says internship + college credit/training = compensation and dual student/employee relationship	Morgan State says no monetary compensation, internship was academic credit only, not employment	Court: Not decided as matter of law for summary judgment; lack of payroll not dispositive but Stewart failed other elements of discrimination claim
Race discrimination under Title VII	Stewart asserts Dr. Welsh made racially charged remarks and grades were motivated by race	Defendants say grades and dismissal were academic decisions by faculty/committee, justified by performance and program rules	Court: Judgment for defendants — no direct evidence, no nexus to adverse action, and no showing of pretext
Retaliation under Title VII	Stewart contends grades were downgraded after he appealed/complained	Defendants say filing a grade appeal is not protected activity alleging racial discrimination; downgrade occurred after independent academic review and some complaints were filed after dismissal	Court: Judgment for defendants — no protected activity shown or causal link established
Breach of contract (internship "Statement of Agreement")	Stewart treats the Statement as an employment contract obligating Morgan State to certain outcomes	Defendants say the Statement was an academic syllabus/outlines goals, lacked consideration and authorization to bind the university	Court: Judgment for defendants — Statement not a binding contract and, even if it were, no breach shown
§ 1983 (constitutional) claims	Stewart alleges denial of right to education and procedural fairness (due process/Equal Protection)	Defendants say no fundamental federal right to education, no facts showing constitutional violation, and Stewart had appeal process	Court: Judgment for defendants — no constitutional violation established

Key Cases Cited

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Haavistola v. Community Fire Co. of Rising Sun, 6 F.3d 211 (4th Cir. 1993) (tests for employee status under Title VII)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Texas Dep't of Community Affairs v. Burdine, 450 U.S. 248 (prima facie case and employer burden in Title VII)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens and standards)
Bouchat v. Baltimore Ravens Football Club, Inc., 346 F.3d 514 (4th Cir.) (nonmoving party must set forth specific facts to create genuine issue)
St. Mary's Honor Center v. Hicks, 509 U.S. 502 (burden and proof in Title VII cases)