Crawford v. Salve Regina University

Background Dr. Linda Crawford, a tenured Spanish professor at Salve Regina University, was terminated in 2022 following student complaints about a class discussion on LGBTQ+ rights and the use of specific terminology. Crawford alleged the complaints were coordinated by a department chair to retaliate against her. She filed suit claiming unlawful discrimination, retaliation, and breach of contract. The district court dismissed her federal claims for failure to state a claim and declined to hear the state law claims. The court’s reasoning The First Circuit panel affirmed the lower court’s decision. The court noted that while the university’s internal investigation and hearing process contained procedural flaws and relied on biased evidence, these issues did not establish a violation of federal law sufficient to survive a motion to dismiss. The court accepted the district court’s conclusion that the allegations, even when viewed in the light most favorable to the plaintiff, did not demonstrate that the termination was motivated by unlawful discrimination or retaliation rather than legitimate pedagogical concerns and performance issues. What it means going forward The decision reinforces the high bar for professors to challenge termination decisions in federal court based on discrimination or retaliation claims when the employer cites performance and pedagogical reasons, even if the internal process was flawed.