Collins v. Alabama State University (MAG+)

CourtDistrict Court, M.D. Alabama
DecidedMarch 27, 2025
Docket2:23-cv-00231
StatusUnknown

This text of Collins v. Alabama State University (MAG+) (Collins v. Alabama State University (MAG+)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Collins v. Alabama State University (MAG+), (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION BRANDEN COLLINS, ) ) Plaintiff, ) ) v. ) CASE NO. 2:23-cv-00231-RAH ) ALABAMA STATE ) UNIVERSITY, ) ) Defendant. )

ORDER Plaintiff Branden Collins filed this pro se action against Alabama State University for disability discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the American with Disabilities Act (“ADA”). On June 28, 2024, Defendant moved for summary judgment. On February 3, 2025, the Magistrate Judge recommended that Defendant’s summary judgment motion be granted. In his Recommendation, the Magistrate Judge found that (1) disability is not a protected characteristic under Title VII; (2) Plaintiff’s resignation and June 30, 2020, written reprimand did not constitute actionable adverse employment actions; (3) Plaintiff failed to provide sufficient evidence that his disability was a but-for cause of his September 2, 2020, schedule change; and (4) Plaintiff did not sufficiently establish that Defendant’s knowledge of his child’s disability was a determining factor behind the schedule change for purposes of an association discrimination claim. On February 18, 2025, Plaintiff filed Objections to the Recommendation. The Court has independently reviewed the file and reviewed, de novo, the Objections and Recommendation. See 28 U.S.C. § 636(b). Upon this Court’s review and consideration of the arguments set forth in the Objections, and for the reasons below, the Court agrees with the Magistrate Judge’s findings and analysis. STANDARD OF REVIEW A. De Novo Review of the Recommendation When a party objects to a Magistrate Judge's Report and Recommendation, the district court must review the disputed portions de novo. 28 U.S.C. § 636(b)(1). The district court “may accept, reject, or modify the recommended disposition; receive further evidence; or resubmit the matter to the magistrate judge with instructions.” Fed. R. Civ. P. 72(b)(3). De novo review requires that the district court independently consider factual issues based on the record. Jeffrey S. ex rel. Ernest S. v. State Bd. of Educ., 896 F.2d 507, 513 (11th Cir. 1990); see also United States v. Opie, 347 F. App’x 495, 499 n.1 (11th Cir. 2009) (per curiam). However, objections to the Magistrate Judge's Report and Recommendation must be sufficiently specific to warrant de novo review. See Macort v. Prem, Inc., 208 F. App’x 781, 784 (11th Cir. 2006) (per curiam) (citation omitted). Otherwise, a Report and Recommendation is reviewed for clear error. Id. (citing Diamond v. Colonial Life & Accident Ins., 416 F.3d 310, 315 (4th Cir. 2005)). B. Summary Judgment Standard “Summary judgment is proper if the evidence shows ‘that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.’” Hornsby-Culpepper v. Ware, 906 F.3d 1302, 1311 (11th Cir. 2018) (quoting Fed. R. Civ. P. 56(a)). “[A] court generally must view all evidence and make all reasonable inferences in favor of the party opposing summary judgment.” Fla. Int’l Univ. Bd. of Trs. v. Fla. Nat’l Univ., Inc., 830 F.3d 1242, 1252 (11th Cir. 2016) (internal quotation marks and citation omitted). However, “conclusory allegations without specific supporting facts have no probative value.” Jefferson v. Sewon Am., Inc., 891 F.3d 911, 924–25 (11th Cir. 2018). If the record, taken as a whole, “could not lead a rational trier of fact to find for the non-moving party,” then there is no genuine dispute as to any material fact. Hornsby-Culpepper, 906 F.3d at 1311 (citing Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986)). The movant bears the initial burden of demonstrating that there is no genuine dispute as to any material fact, and the movant must identify the portions of the record which support this proposition. Id. (citing Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986)). The movant may carry “this burden by demonstrating that the nonmoving party has failed to present sufficient evidence to support an essential element of the case.” Id. The burden then shifts to the non-moving party to establish, by going beyond the pleadings, that a genuine issue of material fact exists. Id. at 1311–12. A genuine dispute of material fact exists when the plaintiff produces evidence that would allow a reasonable factfinder to return a verdict in his favor such that summary judgment is not warranted. See Greenberg v. BellSouth Telecomms., Inc., 498 F.3d 1258, 1263 (11th Cir. 2007) (per curiam). “The mere existence of some factual dispute will not defeat summary judgment unless that factual dispute is material to an issue affecting the outcome of the case.” McCormick v. City of Fort Lauderdale, 333 F.3d 1234, 1243 (11th Cir. 2003) (per curiam) (citation omitted). Only disputes involving material facts are relevant, and materiality is determined by the substantive law applicable. Id. DISCUSSION A. Title VII Claim In total, Plaintiff asserts thirteen Objections. None of them have merit. Under Title VII, an employer is prohibited from “discriminat[ing] against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e-2(a)(1). To prevail on a Title VII claim, a plaintiff may either present evidence that satisfies the burden-shifting framework in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802–04 (1973), or demonstrate “a convincing mosaic of circumstantial evidence that warrants an inference of intentional discrimination,” Lewis v. City of Union City, 918 F.3d 1213, 1220 n.6 (11th Cir. 2019) (en banc) (internal quotation marks and citation omitted). As an initial matter, Plaintiff does not object to the Magistrate Judge’s finding that Defendant is entitled to summary judgment on Plaintiff’s Title VII claim because “disability is not a protected characteristic covered by Title VII.” (Doc. 29 at 8.) The Magistrate Judge’s determination that disability is not a protected characteristic under Title VII is therefore not clearly erroneous. See Branscomb v. Sec’y of Navy, 461 F. App’x 901, 906 (11th Cir. 2012) (per curiam) (stating that disability “is not a characteristic enumerated in Title VII”). Further, because Plaintiff failed to object to the finding, he “waives the right to challenge that finding on appeal” because he “was informed of the time for objecting and the consequences on appeal for failing to object.” Wilson v. Sec’y, Fla. Dep’t of Corr., No. 20-13558, 2022 WL 17176707, at *1 (11th Cir. 2022) (per curiam) (citation omitted); (see doc. 29 at 19–20). Accordingly, the Recommendation is adopted insofar as the Magistrate Judge recommended dismissal of Plaintiff’s Title VII claim. B. ADA Claims 1.

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Bluebook (online)
Collins v. Alabama State University (MAG+), Counsel Stack Legal Research, https://law.counselstack.com/opinion/collins-v-alabama-state-university-mag-almd-2025.