A federal judge in New York has thrown out a discrimination and retaliation suit by an African-American faculty member who was denied a promotion to an administrative position at Suffolk County Community College.
U.S. District Judge Arthur Spatt ruled that Dr. Michelle Cummings-Flower failed to prove that her supervisors had participated in discriminatory hiring procedures, subjected her to racist comments or created a hostile work environment.
In 1997, the college hired Cummings-Fowler as an adjunct faculty member, according to the decision. She became a full-time faculty member in 2000 and was promoted to coordinator of instructional development in 2003. She received no negative performance reviews during her time at the college, Spatt said.
The suit alleged that the college’s vice president for academic and student affairs, who also headed her department, commonly referred to African-Americans as “you people” and college White colleagues by their professional titles while referring to her as “young lady” or “Michelle.”
When she complained to an associate dean, he “launched into a racist rant,” the suit claimed, and told her that “you people are just taking over,” referring to the college president, vice president and two executive deans who were Black.
She claimed those and other racist “comments and attitudes made her feel demeaned, humiliated and less equal than her White peers, as well as put her in a position where she thought she had to constantly prove herself,” the decision said. However, she didn’t follow the college’s complaint procedures, meaning there was no internal investigation.
Cummings-Flower may have subjectively felt pressure, humiliation and inhospitality because of racist and inappropriate remarks, Spatt said, but there wasn’t enough objective evidence to conclude her supervisors intended to discriminate or that “discriminatory intimidation” pervaded the work environment.
