University Fired Black Professor After Being Denied Tenure Due to Race, Federal Agency Charged
SAN DIEGO - Chapman University, a private university in Orange, Calif., will pay $75,000 and furnish other relief to settle a race discrimination lawsuit filed by the U.S. Equal Employment Opportunity Commission (EEOC), the agency announced today.
The EEOC had charged that Chapman's George L. Argyros School of Business & Economics (ASBE) discriminated against Stephanie Dellande, an assistant professor of marketing, because of her race. The EEOC contended that Dellande was denied both tenure and promotion to associate professor in 2006 because she is African-American, despite strong recommendations in her favor by many professional peers. The university discharged her in June 2008 upon a denial of her tenure appeal.
According to the EEOC's suit, Dellande was the first black professor to have been allowed to apply for tenure at the ASBE, and was subjected to a higher standard for obtaining tenure and promotion than her non-black peers.
Race discrimination violates Title VII of the Civil Rights Act of 1964. The EEOC filed suit in U.S. District Court for the Central District of California, Western Division [EEOC v. Chapman University and the Board of Trustees of Chapman University, Case No. LA CV-10-1419-JAK(RNBx)] in September 2010 after first attempting to reach a pre-litigation settlement through its conciliation process. The case was settled during the pendency of the EEOC's appeal with the Ninth Circuit Court of Appeals (Court of Appeal No. 12-56094) after Chapman was granted summary judgment at the district court level.
According to the consent decree settling the suit, aside from the monetary relief, Chapman agreed to designate an internal equal employment opportunity officer; train all ASBE employees on their rights and responsibilities on discrimination in the workplace; maintain a centralized system to track complaints by ASBE faculty members about denial of tenure and discrimination; revise its policies on discrimination and retaliation; and post a notice on the matter at ASBE. The EEOC will monitor compliance with the two-year consent decree.
"The preventive measures that Chapman University has agreed to will go a long way toward creating a discrimination-free environment that encourages reports of discrimination without fear of reprisal," said Anna Y. Park, regional attorney for the EEOC's Los Angeles District Office. "We commend Chapman University for its commitment toward equal access to opportunities there."
Upon learning of the settlement, Dellande said, "Chapman University's actions caught me completely off guard - like a punch in the gut - especially since I was told that I was on track for tenure. In the big scheme of things, it meant that I would not have a seat at the table where policies were made, simply because of my race. However, the outcome is a victory for me. I have deep gratitude and appreciation to the EEOC for helping me through this ordeal."
Marla Stern-Knowlton, local director of the EEOC's San Diego Local Office, added, "Employment decisions should be made based on neutral criteria without regard to race. In entering the agreement with EEOC, Chapman University has taken an important step toward such protections for its employees."
Founded in 1861, Chapman University is a private, non-profit university with programs in seven schools and colleges, and an enrollment of approximately 6,000 undergraduate, graduate and law students.
The EEOC is responsible for enforcing federal laws against employment discrimination. Further information is available at www.eeoc.gov.