In Wallace v. Mary Baldwin University, 2025 WL 1409860 (4th Cir. May 15, 2025), the court affirmed the lower court’s orders dismissing, for failure to sate a claim, her complaints raising claims of sex discrimination and retaliation under Title VII of the Civil Rights Act of 1964.
From the decision:
A plaintiff can establish a discrimination claim under Title VII by two routes: she can provide direct evidence of discrimination, or she can proceed using the burden-shifting framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The McDonnell Douglas framework generally requires a plaintiff to establish a prima facie case for her claim; if she does, the burden then shifts to her employer to provide a non-discriminatory reason for the allegedly discriminatory action, which the plaintiff must then prove is pretextual. See id. at 802-04. Although “an employment discrimination plaintiff need not plead a prima facie case of discrimination to survive a motion to dismiss,” she must “allege[ ] facts that plausibly state a violation of Title VII above a speculative level.” Bing v. Brivo Sys., LLC, 959 F.3d 605, 616-17 (4th Cir. 2020) (internal quotation marks omitted).
We have reviewed the record and find no reversible error. As to Wallace’s retaliation claim, the district court did not err in finding she failed to adequately plead causation. Nor did the district court err in finding Wallace did not adequately plead that Mary Baldwin University’s failure to hire her to teach in the summer of 2021 was the product of discrimination.
Accordingly, based on the foregoing, dismissal was warranted.