Patricia Walker-Swinton v. Philander Smith College, No. 22-1547 (8th Cir. 2023)
Annotate this Case
Philander Smith College fired Plaintiff after she referred to a student as “retarded” for using a cell phone during class. She sued for sex discrimination, retaliation, and breach of contract. After granting summary judgment to the college on the first two claims, the district court declined to exercise supplemental jurisdiction over the third.
The Eighth Circuit affirmed. The court held that Plaintiff has not put forward sufficient evidence of pretext. So summary judgment marks the end of the road for her sex-discrimination claim. Further, the court reasoned that even if the conditions were intolerable, in other words, Plainitff’s own role in provoking these incidents undermines the claim that the college created a workplace full of discriminatory intimidation, ridicule, and insult. Moreover, the court explained once Plaintiff’s federal claims were gone, the district court had no obligation to exercise supplemental jurisdiction over Plaintiff’s Arkansas breach-of-contract claim.
Court Description: [Stras, Author, with Smith, Chief Judge, and Arnold, Circuit Judge] Civil case - Civil rights. Even assuming plaintiff could establish a prima-facie case of gender-based discrimination, the defendant offered legitimate, non-discriminatory grounds for her termination which she failed to show were pretexts, and the district court did not err in granting the defendant's motion for summary judgment on plaintiff's Title VII gender discrimination claim; with respect to plaintiff's hostile work environment claim, she failed to establish she experienced severe and pervasive harassment sufficient to alter the conditions of her employment, especially in light of her conduct in provoking the incidents; plaintiff failed to exhaust her unequal pay claim; the district court did not err in dismissing plaintiff's state-law based breach-of-contract claim.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.