Clark v. Claremont University Center

8 Cal. Rptr. 2d 151 (1992)

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Clark v. Claremont University Center

California Court of Appeal
8 Cal. Rptr. 2d 151 (1992)

Facts

Reginald Clark (plaintiff) was an African American assistant professor in the English Department at the Claremont Graduate School (Claremont), a subdivision of the Claremont University Center (defendant). Clark applied for tenure during his fifth year of teaching, but tenure was ultimately denied after a long review process. Claremont’s review process was multitiered: (1) review by the academic department; (2) review by an academic committee; (3) a recommendation to the board of trustees by the dean of faculty, executive dean, and president; and (4) the ultimate decision by the board of trustees. Claremont, as a research institution, placed heavy emphasis on scholarly achievement. However, there were no exact guidelines. Some faculty members stressed quality over quantity. Claremont also considered student evaluations and teaching performance. During his time at Claremont, Clark was told by several faculty members that he would probably receive tenure if he published his book. Clark eventually published his book right before applying for tenure and received positive reviews. Additionally, Clark published and presented several papers and taught multiple seminars, for which he received significant support and praise. Clarke’s review process was marred by several comments that he overheard faculty and committee members make while conferring during meetings of his academic department, including: “White people have rights too,” and “we are not under any obligation to have Blacks, because we are a private college.” The faculty member who made the former comment wrote a negative letter to the academic committee. Some faculty expressed support for Clark because of his race. No vote at any stage of the process was unanimous. There was no evidence of discriminatory remarks made by members of the academic committee or the president, though both had access to reports from the meetings. Clark filed a discrimination suit under California’s Fair Housing and Employment Act. A jury sided with Clark and awarded one million dollars in compensatory damages. In doing so, the jury found that Clark was denied tenure because of his race. Claremont raised multiple issues on appeal, including insufficiency of the evidence. Claremont argued that even if discriminatory remarks were made, they did not affect the ultimate decision, because the review process was compartmentalized.

Rule of Law

Issue

Holding and Reasoning (Ortega, J.)

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