BENNETT MACINTYRE V. CARROLL COLLEGE, No. 21-35642 (9th Cir. 2022)
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Plaintiff sued Carroll College, alleging that it refused to renew its contract as a golf coach after he complained about gender inequity at the college’s athletic department. The district court ruled that Plaintiff failed to make the prima facie case that the nonrenewal of the contract was an adverse employment action.
The Ninth Circuit reversed the district court’s summary judgment in favor of Defendant. The panel held that the refusal to renew a contract may be an adverse employment action for a Title IX retaliation claim because it could deter a reasonable employee from reporting discrimination. The panel remanded the case to the district court to consider Carroll College’s alternative bases for summary judgment.
Court Description: Employment Discrimination The panel reversed the district court’s summary judgment in favor of the defendant in a Title IX retaliation suit and remanded. Bennett MacIntyre sued Carroll College, alleging that it refused to renew his contract as a golf coach after he complained about gender inequity at the college’s athletic department. The district court ruled that MacIntyre failed to make the prima facie case that the nonrenewal of the contract was an adverse employment action. The panel reversed, holding that the refusal to renew a contract may be an adverse employment action for a Title IX retaliation claim because it could deter a reasonable employee from reporting discrimination. The panel remanded the case to the district court to consider Carroll College’s alternative bases for summary judgment.
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