Stewart v. Morgan State University, 46 F. Supp. 3d 590

Background

Troy Stewart, an African-American Ed.D. candidate at Morgan State University, received two C grades and an "incomplete" in an internship course in Spring 2010 and was dismissed from the program by November 2010 under program rules (two Cs can trigger dismissal).
Stewart alleged Dr. Benjamin Welsh (internship supervisor) made disparaging comments and graded him unfairly; he appealed grades and received review by departmental committee which upheld the grades and converted the incomplete to an F.
Stewart filed administrative charges and obtained an EEOC right-to-sue letter, then sued Morgan State and several individuals asserting Title VII race discrimination and retaliation, breach of contract, and Section 1983 constitutional claims.
Defendants moved for summary judgment; they argued Stewart was not an employee for Title VII purposes, the dismissal was an academic decision, no contract existed in the Statement of Agreement, and no constitutional violation occurred.
The court concluded the Statement of Agreement was not a binding contract, there was no evidence linking alleged racial remarks to the dismissal, the academic-review process supported the academic decision, and Stewart failed to prove retaliation or any constitutional violation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title VII — employment status	Stewart argues his internship and college credit amounted to an employment relationship/compensation	Morgan State says no monetary compensation, internship was academic not employment	Court: lack of pay alone does not foreclose employee status, but summary judgment not granted on this narrow point; claims fail on other grounds
Title VII — race discrimination	Stewart contends grades and dismissal were racially motivated by Welsh's comments/actions	Defendants say grades and dismissal were academic determinations by committee based on poor work	Court: no direct nexus between alleged remarks and dismissal; no evidence of pretext; discrimination claim failed
Title VII — retaliation	Stewart claims grades were worsened after he appealed/complained	Defendants say grade appeal is not protected activity and timing does not support causation	Court: filing grade appeal/complaints here not a protected activity causing adverse action; retaliation claim failed
Breach of contract	Stewart treats the signed "Statement of Agreement" as a binding employment contract obligating grade outcomes	Defendants say the Statement was an internship syllabus/goals, not a contract and lacked consideration/authorized signature	Court: Statement is not a contract enforcing a grade promise; breach claim failed
§ 1983 — constitutional claims	Stewart alleges denial of equal protection and denial of right to appeal discriminatory grades	Defendants say no constitutional right to particular educational outcome and no constitutional violation shown	Court: no constitutional violation; § 1983 claims failed

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (established burden-shifting framework for disparate-treatment claims)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard; genuine dispute of material fact)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens and nonmoving party obligations)
Haavistola v. Community Fire Co. of Rising Sun, 6 F.3d 211 (Fourth Circuit test for employee status under Title VII)
Texas Dept. of Community Affairs v. Burdine, 450 U.S. 248 (prima facie case and burden-shifting in employment discrimination)
St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (McDonnell Douglas framework and proof of discriminatory intent)
Brinkley v. Harbour Recreation Club, 180 F.3d 598 (direct evidence requires nexus between remark and employment decision)