Dr. Linda Crawford was a tenured Spanish professor at Salve Regina University who had taught at the University since 2004. The events leading to her termination began during a November 2021 Spanish American Culture and Civilization class addressing gender and sexuality in Latin America. Crawford had assigned a reading that used outdated terminology to refer to transgender individuals, which a student considered offensive. During class, the student objected to the terminology and became outwardly upset. Several students subsequently met with Crawford’s department chair, who Crawford alleged encouraged them to keep a running list of criticisms about Crawford and to submit written complaints about her teaching. One student identified himself as a transgender gay man and criticized Crawford, in part, because she was a “white straight cis woman”; another complained about derogatory language concerning transgender people and expressed that classrooms should be safe spaces.
The University subsequently held a group meeting with students regarding Crawford’s classes, during which some students accused her of using offensive language and hateful rhetoric toward LGBTQ+ individuals and people of color. Crawford alleged that she was neither informed of nor permitted to participate in the meeting and that the University failed to adequately investigate or verify the students’ allegations. The University thereafter restricted some of her duties and, approximately six weeks later, terminated her employment for cause, citing continued misconduct, failure to communicate, and failure to satisfy faculty responsibilities. According to Crawford, the University President identified the November classroom incident as the “catalyst” for her termination while also citing a longer history of concerns regarding her teaching.
Crawford appealed her termination through the University’s internal faculty process. A Faculty Hearing Board ultimately upheld the decision with a 3-2 vote. The majority acknowledged problems with the investigation, including that some evidence had been collected prejudicially, haphazardly, and without adequate independence. Nevertheless, it concluded that Crawford had regularly used language that minimized others or promoted hurtful stereotypes, and it identified additional longstanding concerns involving her responsiveness to students and colleagues, grading practices, and classroom conduct. The majority noted that although Crawford’s lessons were crafted to explore stereotypes and foster educational dialogue, Crawford did not teach those topics in a culturally responsive way. The dissenting members believed the termination process was unfair and that evidence had been selectively gathered to support a predetermined outcome.
After the University’s Board of Trustees unanimously affirmed her termination, Crawford sued, asserting discrimination based on gender, race, sexual orientation, age, and religion under federal and Rhode Island law, as well as hostile work environment and retaliation claims. The trial court dismissed the discrimination-related claims, and the First Circuit affirmed.
The First Circuit focused primarily on causation. Although Crawford identified comments by students referencing her race, gender, and sexual orientation, the Court found no factual allegations connecting those comments to the University officials who actually decided to terminate her. For example, the student’s statement that Crawford was a “cis white woman” could potentially demonstrate that student’s bias, but the student was not a decisionmaker. Crawford did not allege facts showing that University decisionmakers endorsed that view, relied on it, or terminated her because of her protected characteristics.
The Court reached a similar conclusion regarding Crawford’s allegations that her department chair encouraged students to complain about her. Crawford alleged that the chair was retaliating because of prior disagreements and a grievance she had filed against him, but she did not explain how those disputes related to a protected characteristic. Likewise, allegations that unidentified individuals objected to Crawford teaching certain subjects because she was a “cis white woman” were insufficient because Crawford did not identify who made the statements, when they were made, or whether they were communicated to or relied upon by the individuals responsible for her termination.
The Court also rejected Crawford’s age and disparate-treatment theories. Her allegation that a male administrator accused of other misconduct received more favorable treatment lacked sufficient information to establish that he was similarly situated to Crawford. Likewise, allegations that she had been called “old school,” that a student sought an advisor with “fresh ideas and perspectives,” and that younger faculty received better offices were not tied to the individuals responsible for terminating her.
The First Circuit also affirmed dismissal of Crawford’s hostile work environment claims. Although Crawford alleged numerous insults and accusations, including that she was racist, transphobic, homophobic, and hostile toward LGBTQ+ individuals and people of color, the Court explained that criticism of an employee’s perceived views about protected groups is not necessarily harassment because of the employee’s own protected status. Thus, even potentially harsh or offensive criticism did not establish that Crawford herself was being targeted because of her race, sex, sexual orientation, age, or religion.
Finally, Crawford’s retaliation claims failed because she did not sufficiently allege protected activity occurring before her termination. She had previously filed a grievance against her department chair, but she did not allege that the grievance concerned discrimination prohibited by Title VII or Title IX. In addition, her participation in the internal proceedings challenging her termination could not support the claim because those proceedings occurred after the termination decision.
Accordingly, the First Circuit affirmed dismissal of Crawford’s claims.
Crawford v. Salve Regina Univ. (1st Cir. 2026) 178 F.4th 734.
Note:
Although the University ultimately prevailed on the discrimination claims, its own Faculty Hearing Board identified significant shortcomings in the investigation. A fair investigation that gathers information from appropriate sources, allows the employee to respond, and clearly documents the basis for the ultimate decision remains an important practice.