66 F.4th 168
4th Cir.2023Background:
- In May 2017 Summer Lashley was hired on a one-year contract to teach criminal justice and serve as program director at Spartanburg Methodist College (SMC).
- From Sept–Dec 2017 Lashley reported alleged harassment of female students to SMC’s HR/Title IX coordinator; she also raised complaints about mold in her office beginning Jan 2018 and requested an ADA accommodation form but never returned it.
- SMC supervisors documented recurring problems: disorganized classes, overly familiar relationships with a work-study student, repeated conflicts with faculty, and frequent complaints by Lashley that she did not fit at SMC.
- After informing Lashley on Feb 13, 2018 that her contract would not be renewed, colleagues reported that Lashley made threatening remarks; SMC’s president terminated her on Feb 16, 2018 citing unprofessional and threatening interactions.
- Lashley sued under federal and state law (ADA and Title IX theories among others); the district court granted summary judgment to SMC on all federal claims and remanded state claims; Lashley appealed the ADA discrimination, ADA retaliation, ADA unlawful health-inquiry, and Title IX retaliation claims.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA retaliation (requesting accommodation) | Lashley says requesting an accommodation and reporting health issues was protected activity and led to non-renewal/termination | SMC says decisions were based on poor fit, professional conflicts, and safety concerns—nonretaliatory reasons | Affirmed for SMC: SMC offered legitimate reasons and Lashley failed to show pretext or causal link |
| Title IX retaliation (reporting student misconduct) | Lashley contends she engaged in protected Title IX activity by assisting female students and was retaliated against | SMC says decisionmakers were unaware of her Title IX reports and adverse actions were for nonretaliatory reasons | Affirmed for SMC: no evidence decisionmakers knew of protected activity or that reasons were pretextual |
| ADA unlawful health inquiry | Lashley contends supervisor demanded private medical details in an unlawful manner | SMC says supervisor reasonably inquired because Lashley had publicly reported health problems and missed/rescheduled classes; inquiry was job-related and limited | Affirmed for SMC: objective standard met—inquiry was job-related and not overly intrusive |
| ADA failure-to-accommodate | Lashley claims SMC failed to accommodate her Crohn’s/gastrointestinal (and alleged other) conditions | SMC says Lashley never completed the interactive process or returned accommodation form and gave no specifics on needed accommodations | Affirmed for SMC: Lashley failed to prove notice and to engage in the interactive process, so no refusal-to-accommodate shown |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for burden-shifting in discrimination/retaliation cases)
- Jackson v. Birmingham Bd. of Educ., 544 U.S. 167 (Title IX private right of action includes retaliation claims)
- Texas Dep’t of Cmty. Affs. v. Burdine, 450 U.S. 248 (employer’s burden to articulate legitimate reasons)
- Reeves v. Sanderson Plumbing Prod., Inc., 530 U.S. 133 (production vs. persuasion at summary judgment)
- Foster v. Univ. of Maryland-E. Shore, 787 F.3d 243 (but-for causation in retaliation claims)
- Cowgill v. First Data Techs., Inc., 41 F.4th 370 (elements of ADA failure-to-accommodate claim)
- Coffey v. Norfolk S. Ry. Co., 23 F.4th 332 (objective test for job-related medical inquiry)
- Wilson v. Dollar Gen. Corp., 717 F.3d 337 (employee’s duty to make adequate accommodation request to trigger employer obligations)