Maras v. Curators of the University of Missouri, No. 19-2875 (8th Cir. 2020)
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Maras's application for tenure as an associate professor at the University of Missouri Department of Educational, School and Counseling Psychology was denied. She filed suit, claiming discrimination on the basis of sex, citing the Missouri Human Rights Act and Title VII, 42 U.S.C. 2000e-2(a)(1), and violations of the implied covenants of good faith and fair dealing in her employment contract. The district court granted the defendants summary judgment.
The Eighth Circuit affirmed. Describing the university's tenure-review process as “elaborate and painstaking,” the court noted that numerous people over four years expressed concerns about Maras's record of scholarship. Many throughout the application process, including people outside the university, expressed similar concerns. That widely shared opinion strongly supports the university's proffered reason for tenure denial. The comparators Maras identified are not similarly situated in all relevant respects to Maras; they did not share the same ultimate decision-maker. One comparator was in a completely different department. Each of them had several positive recommendations at many steps in the tenure process, while Maras did not; it is not obvious that their records of scholarship were no better than Maras's. Maras did not show "that the circumstances permit a reasonable inference of discriminatory animus."
Court Description: [Arnold, Author, with Colloton and Kelly, Circuit Judges] Civil Case - Employment Discrimination. Following a denial of tenure as associate professor, Maras sued the university and participants in the tenure-review process, alleging sex discrimination under state and federal law and breach of implied covenant of good faith and fair dealing. The district court's grant of summary judgment to the defendants is affirmed, as Maras failed to show circumstances to permit a reasonable inference of discriminatory animus or that her sex contributed to the university's decision.
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