Dixon v. University of Toledo

Crystal Dixon (plaintiff) was the interim associate vice president for human resources at the University of Toledo (the university) (defendant). In her position, Dixon answered grievances, issued disciplinary and corrective action, focused on task forces, supervised about 40 employees, oversaw the administration of benefits, set compensation, and made presentations at town-hall meetings. Dixon responded to a column by Michael Miller, the editor-in-chief of the Toledo Free Press, that compared the civil-rights movement with the gay-rights movement. Miller then criticized the university’s failure to provide health insurance to same-sex couples. In Dixon’s response, Dixon rejected the comparison, saying that “choosing the homosexual lifestyle” was incomparable to being Black. Dixon also defended the university, claiming that all employees had different benefits plans. The university placed Dixon on paid administrative leave. Lloyd Jacobs, the university president, wrote a column in the Toledo Free Press to clarify that Dixon’s views did not align with the university’s values. After a hearing held by the university, the university fired Dixon because her public position directly contradicted university policies, procedures, and values. Dixon filed a lawsuit against the university and Jacobs in the United States District Court for the Northern District of Ohio, alleging a First Amendment retaliation claim and a Fourteenth Amendment disparate-treatment claim. Dixon, the university, and Jacobs cross-motioned for summary judgment. The court granted summary judgment to the university and Jacobs. Dixon appealed.