113 F.4th 25
1st Cir.2024Background
- Lupe Stratton worked at Bentley University from 2016 to 2018, alleging discrimination based on gender, race, disability, and national origin, as well as retaliation for raising these complaints.
- Stratton claimed she was subjected to a hostile work environment, denied reasonable accommodations for her disability, and faced retaliation following complaints to HR.
- She was placed on a performance improvement plan after her complaints, which she argued was retaliatory, and later resigned, claiming constructive discharge.
- Stratton filed suit under Title VII, the ADA, FMLA, and Massachusetts anti-discrimination statutes, alleging discrimination, retaliation, interference with medical leave, and failure to accommodate.
- The district court granted summary judgment for Bentley on all claims, finding no actionable discrimination or retaliation and sufficient accommodations provided.
- On appeal, Stratton challenged the grant of summary judgment and the district court's handling of her motion to alter/amend the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constructive Discharge (Title VII/151B) | Workplace hostility and discrimination forced resignation | Alleged actions not objectively intolerable | No constructive discharge; no adverse action |
| Retaliation (Title VII/151B) | Performance plan & increased hostility were retaliation | Actions were for unsatisfactory performance, not retaliation | No causation; supervisors did not know of protected activity |
| FMLA Interference/Retaliation | Hostile acts discouraged FMLA leave; retaliation for using it | Approved all valid requests; negative actions pre-dated leave | No interference or actionable retaliation |
| Disability Accommodation (ADA/151B) | Denied remote work and meaningful dialogue for accommodation | Provided adequate alternative on-campus accommodations | No denial of reasonable accommodation or related harm |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination claims)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (clarifies broader standard for "materially adverse" actions in retaliation claims)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (2013) (Title VII retaliation requires "but-for" causation)
- Marrero v. Goya of P.R., Inc., 304 F.3d 7 (1st Cir. 2002) (standard for constructive discharge)
- Morales-Vallellanes v. Potter, 605 F.3d 27 (1st Cir. 2010) (adverse employment action defined)
- Hodgens v. Gen. Dynamics Corp., 144 F.3d 151 (1st Cir. 1998) (FMLA interference and retaliation standards)
- O'Rourke v. City of Providence, 235 F.3d 713 (1st Cir. 2001) (elements of hostile work environment under Title VII)
- Freadman v. Metro. Prop. & Cas. Ins. Co., 484 F.3d 91 (1st Cir. 2007) (failure-to-accommodate framework under ADA)