Weiss v. Dartmouth College

2014 DNH 221
CourtDistrict Court, D. New Hampshire
DecidedOctober 17, 2014
Docket13-cv-376-LM
StatusPublished

This text of 2014 DNH 221 (Weiss v. Dartmouth College) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Weiss v. Dartmouth College, 2014 DNH 221 (D.N.H. 2014).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Lys Ann Weiss

v. Civil No. 13-cv-376-LM Opinion No. 2014 DNH 221 Dartmouth College

O R D E R

The Plaintiff, Lys Ann Weiss, was – and remains – employed

by the Defendant, Dartmouth College. In this lawsuit, Ms. Weiss

alleges that she was the victim of unlawful discrimination and

harassment on the basis of her age and gender, and that her

superiors retaliated against her for voicing her concerns. Now,

Dartmouth has filed a motion for summary judgment which, for the

reasons that follow, is GRANTED.

Factual Background1

Ms. Weiss was hired in 2009 (at the age of 56) as the

Managing Editor of the publishing department at Dartmouth, which

operates under the trade name University Press of New England

(“UPNE”). Compl. ¶ 4. As Managing Editor, Ms. Weiss was

principally responsible for ensuring that UPNE publications were

thoroughly checked for errors, that UPNE had all of the

1 The facts are summarized from the complaint (Document No. 1; cited as “Compl.”) and the briefs and exhibits filed in connection with the motion for summary judgment. Unless noted, the facts are not in dispute. necessary legal permissions to publish its materials, and that

all indexes and manuscripts were prepared accurately and in a

timely fashion. Dartmouth’s Mem. in Supp. of Mot. for Summ. J.

(“Dartmouth’s Mem.”) 2, Document No. 12-1.

Ms. Weiss reported directly to Eric Brooks, the Assistant

Director of Design and Production. Compl. ¶ 5. Mr. Brooks, in

turn, reported to Michael Burton, the Press Director. Id.

Another employee, Phyllis Deutsch, was UPNE’s Editor-in-Chief

and also reported to Mr. Burton, making her a peer of Mr.

Brooks. Id.

The allegations in this case largely involve the purported

favoritism of young, female employees by Mr. Brooks, and the

refusal by Ms. Deutsch and Mr. Burton to remedy the situation.

The complaint alleges many examples of this favoritism:

 At a meeting in April 2011, Mr. Brooks so “lavishly praised” the work of a young, female production assistant that meeting attendees were made to feel “uncomfortable.” Id. ¶ 9. Mr. Brooks later expressed his “personal devastation” when this same production assistant announced her impending departure from UPNE. Id.

 At another meeting attended by the same young, female production assistant, Mr. Brooks admonished Ms. Weiss and another attendee to “keep quiet” because the young production assistant “want[ed] to say something.” Id. ¶ 10.

 Mr. Brooks “spent a considerable amount of time” with another young, female assistant. Id. ¶ 11.

2  In July 2011, Ms. Weiss asked Mr. Brooks if a young, female production assistant could mail an envelope, but Mr. Brooks said that Ms. Weiss should mail it herself because the young production assistant’s time was “more valuable.” Id. ¶ 14.

 In March 2012, Mr. Brooks informed Ms. Weiss “testily” that a young, female designer would be allowed to temporarily store page proofs in her office, a departure from standard office procedure. Id. ¶ 19.

 In April 2012, Mr. Brooks defended the work of a young, female production assistant when confronted by Ms. Weiss with perceived shortcomings in the work. Id. ¶ 23.

 At approximately the same time, Mr. Brooks told Ms. Weiss to “butt out” when Ms. Weiss came to him with concerns about email correspondence between a young, female designer and a freelance editor. Id. ¶ 24.

 At a meeting in July 2012, Mr. Brooks “doted on [a young, female production assistant’s] recent experience at volleyball camp.” Id. ¶ 31.

 Mr. Brooks allegedly held doors for other employees, but not for Ms. Weiss. Dartmouth’s Mem. 4.

The complaint alleges that Ms. Weiss initially brought her

concerns regarding the perceived favoritism to the attention of

Ms. Deutsch, who indicated that she had observed the behavior

herself, and who promised that she would address the situation

with Mr. Burton. Compl. ¶ 12. Separately, Ms. Weiss raised the

issue directly with Mr. Burton at a meeting in May 2011; Mr.

3 Burton allegedly indicated that the favoritism was already on a

list of issues to discuss with Mr. Brooks.2 Id. ¶ 13.

Prior to the first of these events, Mr. Brooks had

expressed concern to Ms. Weiss regarding her unsatisfactory

attendance and failure to meet deadlines. In November 2010, Mr.

Brooks wrote an email to Ms. Weiss, stating “I’m just starting

to get a little bit concerned about people in the department not

being here by 9:00 at the latest on a more consistent basis and

wanted to share my general expectations with you.” See Exh. H

to Aff. of Eric Brooks, Document No. 12-16. Then, in May 2011,

Ms. Weiss received an annual review that noted that “[w]hereas,

in general, [Ms. Weiss] and her staff have done a very good job

adhering to schedules, there have been a few spells and a few

instances where books have fallen off schedule in ways not

entirely explicable by the complications inherent in the

projects themselves.” See id. at Exh. C, Document No. 12-11.

During approximately the same period of time, Mr. Brooks

and Mr. Burton began noting friction between Ms. Weiss and

others at UPNE. In March 2011, Mr. Burton contacted Dartmouth’s

Human Resources Department with concerns that Ms. Weiss had

reacted inappropriately to Mr. Brooks having made a managerial

2 Ms. Weiss recorded many of these events in a lengthy diary that she kept from July 2011 until her departure from UPNE in September 2012. See Def.’s First Req. for Admis. to Pl., Document No. 12-7. 4 decision without consulting her. Aff. of Michael Burton ¶ 8,

Document No. 12-17. According to Mr. Burton, Ms. Weiss “was

absent [from] work for two days [after the incident], and

refused to work on a project because she was upset at not being

consulted.” Id.

The record suggests that Mr. Brooks’s November 2010 email

did little to alter Ms. Weiss’s unsatisfactory pattern of

attendance. Between December 2011 and April 2012, Ms. Weiss was

absent from the office for eighteen days and missed at least a

portion of twenty-three additional days. Aff. of Eric Brooks ¶

15, Document No. 12-8. At the same time, many of the projects

for which Ms. Weiss had responsibility were significantly behind

schedule. See id. at Exh. D, Document No. 12-12.

And, Dartmouth suggests that Ms. Weiss continued to be a

source of interpersonal strife and office friction. For

example, in May 2012, Mr. Brooks gave Ms. Weiss her annual

employment evaluation. See Exh. C to Aff. of Michael Burton,

Document No. 12-20. In addition to noting her attendance

shortcomings, Mr. Brooks wrote that “[o]f the greatest concern

is that . . . [Ms. Weiss] has become increasingly uncooperative

and intransigent. Simultaneously, she has been . . .

inexplicably inhospitable toward two of the new members of the

department . . . . For example, her reaction to errors in

composition . . . made one colleague feel harassed.” Id.

5 After Ms. Weiss submitted a response to the evaluation,

Dartmouth arranged for mediation between Ms. Weiss and her

supervisors; this was unsuccessful.3 Compl. ¶¶ 26-27.

Thereafter, the complaint suggests that Ms. Weiss was prohibited

from speaking with coworkers about non-work-related issues and

was required to arrive at work by 9:00 a.m.4 Id. ¶¶ 27-28.

The parties offer competing interpretations of these

events.

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