01-29-2020
Kristin Naca worked as an assistant professor of poetry for Macalester College. In 2015, as she was being considered for tenure at the college, a recent graduate accused her of initiating a sexual relationship. This student had worked with Naca for three years but shortly before graduation, Naca had invited the student to her home and they began a sexual relationship. The student told the school that she felt pressured to have this relationship. Macalester terminated Naca who argued that there was no rule against relationships with former students. However, the college found that she had initiated the relationship while the student was still enrolled, a violation of policy.Naca filed a lawsuit, alleging discrimination based on sex, national origin, and failure to accommodate. The Eighth Circuit Court of Appeals ruled in favor of the college, affirming the judgment of the federal district court. The district court stated “[n]othing about the circumstances of this case gives rise to an inference of discrimination.” Naca had no issues in her career at Macalester, and she was being considered for tenure. There were no changes to her “race/ancestry, sex, sexual orientation, or religion; what changed is that a former student made a formal complaint of sexual misconduct.” The circuit court noted that even if the district court was incorrect in its determination about Naca stating a prima facie case of discrimination, the college had put forth a legitimate non-discriminatory reason for its decision, and Naca failed to provide sufficient evidence of pretext to overcome it.