Craine v. Trinity College

Here, the plaintiff was hired by the defendant as an assistant professor. Throughout her employment, she was reappointed and complimented by the appointments and promotions committee. In her positions, the plaintiff taught, researched, and participated in service efforts for the defendant. Id. at 629-30. Despite that the plaintiff published several articles, taught students and supervised student research, during her tenure review in her sixth year of employment, she was denied tenure. Id. at 632-33. The tenure committee found the plaintiff was a “good teacher but not an extraordinary one,” and found her service to the school to be adequate. However the committee found her research and scholarship was inadequate, since she had only published one article in a refereed professional journal (notwithstanding that she had other publications). Id. at 634. The plaintiff claimed that the tenure process as it applied to her was discriminatory. The court noted that to establish a prima facie case of gender discrimination in the work environment, a plaintiff must show: “(1) she was a member of a protected class; (2) she was qualified for her position; (3) she was discharged; and (4) the termination occurred under circumstances giving rise to an inference of discrimination.” Id. at 225-26. The court noted to meet the fourth element, the plaintiff must show that “she was treated less favorably than comparable male employees in circumstances from which a gender-based motive could be inferred.” Id. at 638. Once a prima facie case is established, to succeed on a gender discrimination claim, the plaintiff must go further to show that the defendant was motivated by an intent to discriminate against the plaintiff in its acts.