White-Goyzueta v. Ivy Tech Community College of Indiana
3:23-cv-00591
| N.D. Ind. | Jun 20, 2025Background
- Dr. Karen White-Goyzueta, an African-American woman, began employment with Ivy Tech Community College as Vice Chancellor of Academic Affairs in August 2021.
- She received negative performance reviews and was placed under extended probation due to concerns about her leadership and interpersonal skills.
- White-Goyzueta filed an EEOC charge in March 2022 alleging race discrimination and retaliation concerning Ivy Tech's application of its anti-nepotism policy and hostile work environment.
- Although Ivy Tech sought to terminate her, the action was delayed until her EEOC charge was resolved in September 2022 via a settlement and withdrawal of her complaint.
- In November 2022, after another incident involving insubordination, White-Goyzueta was terminated and subsequently brought retaliation claims under Title VII and § 1981; discrimination and tortious interference claims were abandoned at summary judgment.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Retaliation – Causation | Termination was caused by her prior EEOC charge | Termination was based on documented, ongoing performance issues | No genuine issue of causation found; Summary judgment for defendant |
| Retaliation – Direct Evidence | Claimed president’s statement indicated animus | Statement amounted to inadmissible double hearsay | No admissible direct evidence of animus |
| Retaliation – Circumstantial (timing/statements) | Timing and HR comments suggest pretext and animus | Timing too remote; comments reflect awareness, not retaliation | Insufficient circumstantial evidence; no triable issue |
| Pretext | Termination justification (laughing incident) mere cover | Documented performance issues and HR procedures justified decision | No evidence of pretext; reason accepted |
Key Cases Cited
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (retaliation under Title VII defined and distinguished)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for proving discrimination and retaliation)
- Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (Title VII retaliation claims require 'but for' causation)
- Boss v. Castro, 816 F.3d 910 (mere timing is insufficient for causation in retaliation claims)
- Argyropoulos v. City of Alton, 539 F.3d 724 (lengthy time gaps defeat inference of retaliatory causation)