Crawford v. Carroll
United States Court of Appeals for the Eleventh Circuit
529 F.3d 961 (2008)
- Written by Jennifer Flinn, JD
Facts
Jacquelyn Crawford (plaintiff), who was African American, was the manager of classification and compensation at Georgia State University (defendant). Crawford’s direct supervisor was Barbara Carroll (defendant), the assistant vice president for human resources. Carroll’s supervisor was Katherine Johnston (defendant), the vice president of finance and administration. Both Carroll and Johnston were Caucasian. Issues arose between Crawford and Carroll, leading Crawford to complain to superiors about discriminatory behavior by Carroll. The university began accepting applications for the newly-created position of director of classification and employment, for which Crawford applied. There was disagreement between Carroll, Johnston, and other members of university management as to which candidate to hire. There was disagreement, too, as to whether the position was even needed. The university posted the position a total of three times, and Crawford applied all three times. Crawford was selected for an interview only once. No candidate was ever hired for the position. Crawford received a negative performance evaluation from Carroll, meaning she would not be eligible for a merit pay increase. Crawford submitted both an internal complaint and a complaint with the Equal Employment Opportunity Commission, alleging racial discrimination and retaliation. Subsequently, Jerry Rackliffe assumed Johnston’s duties and retroactively increased Crawford’s salary in order to settle her complaint. Crawford filed a lawsuit against the university, Carroll, and Johnston, alleging violations of Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause. The district court granted summary judgment in favor of the university, Carroll, and Johnston on all claims. Crawford appealed.
Rule of Law
Issue
Holding and Reasoning (Rodgers, J.)
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