Barbara Lindsay sued Denver Public Schools (DPS) and Stephanie Donner in the District of Colorado. The District Court granted summary judgment to DPS and Donner. Lindsay appealed.
Plaintiff’s Factual Allegation
Barbara Lindsay, who was the Director of Workforce Development and Career Services at Emily Griffith Technical College (EGTC), sued DPS and Stephanie Donner following her termination in July 2019. Lindsay alleged her dismissal was retaliatory, linked to her opposition to racist remarks about a candidate during the hiring process for the Executive Director (ED) position at EGTC, and her assistance to that candidate in filing employment-discrimination charges. Her claims were brought under several laws, including Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 1981 and 1983, and the Colorado Anti-Discrimination Act (CADA).
Summary of Arguments and Court’s Rulings:
The district court initially granted summary judgment for DPS and Donner on all claims, citing a lack of sufficient evidence to link Lindsay’s termination with her alleged protected activities. The appellate court, in reviewing this decision, delved into whether there was a causal relationship between Lindsay’s termination and her engagement in protected activities, a crucial element in her retaliation claims under the various statutes.
In their analysis, the appellate court concurred with the district court’s finding that Lindsay failed to support the causation between her termination and her protected activities. Her arguments were considered speculative, particularly the lack of demonstrable knowledge by the decision-makers, including Donner, about her opposition to the discriminatory comments or her involvement in the discrimination charges. The court emphasized the critical absence of evidence that those responsible for her termination were aware of her protected activities. The appellate court’s conclusion affirmed the district court’s grant of summary judgment on all claims. They underscored that Lindsay did not present adequate evidence to suggest that her termination was due to her engagement in protected activities. Without demonstrable causation between the protected activities and the termination, her claims could not be sustained.
Schrag on Law 