Theidon v. Harvard University, No. 18-1279 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed the judgment of the district court denying Plaintiff's claims of sex discrimination and retaliation on summary judgment and declining Plaintiff's request to alter or amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no reversible error in the proceedings below.
This complaint stemmed from Plaintiff's unsuccessful pursuit of tenure within Harvard University's Anthropology Department. Plaintiff alleged that Harvard denied her tenure on the basis of sex discrimination and retaliation for engaging in protected conduct in violation of several state and federal antidiscrimination laws. The district court dismissed Plaintiff's claims on summary judgment and then denied Plaintiff's Rule 59(e) motion to alter or amend the summary judgment. The First Circuit affirmed, holding (1) the district court did not err in finding that Plaintiff did not meet her burden of showing Harvard's stated reason for denying tenure was merely pretext for discrimination; (2) because Plaintiff could not establish a causal link between her protected activity and the adverse employment decision, her retaliation claims failed; and (3) the district court did not err in denying Plaintiff's Rule 59(e) motion.