The Seventh Circuit held that the District Court did not err in granting Columbia College's motion for summary judgment in employee’s Title VII action alleging that she was terminated from her part-time instructor position because of her race and/or national origin.
Columbia College investigated a complaint received from one of her students alleging that Smiley had isolated and singled him out for being Jewish. The record showed that Columbia College made termination decision after interviewing the student and Smiley, during which Smiley acknowledged that her teaching style involved goofing around with her students and teasing them. Therefore, Columbia College could properly conclude that Smilely's termination was warranted based upon expectation that its instructors would teach classes in professional manner.
The Seventh Circuit rejected Smiley's claim that Columbia College's investigation into the student complaint was deficient because it failed to interview other students in her class, where record showed that Columbia College's other investigations occurred in similar manner.
Further, Columbia College's procedures did not require it to contact other witnesses to alleged discriminatory conduct, and the school’s investigation of the complaint does not indicate that its reason for telling her it would not ask her to teach more classes was pretextual.