You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Cass v. Town of Wayland

Citation: 383 F. Supp. 3d 66Docket: Civil Action No. 17-11441-PBS

Court: District Court, District of Columbia; May 30, 2019; Federal District Court

Narrative Opinion Summary

The case involves a former athletic director who claims his contract was not renewed due to retaliation for raising concerns about Title IX gender equity and budget practices. The plaintiff filed multiple claims against the defendants, including retaliation under Title IX and the Massachusetts Whistleblower Act, malicious prosecution, intentional infliction of emotional distress, defamation, and constitutional violations. The court partially granted the defendants' motion for summary judgment, allowing some claims to proceed to trial due to genuine disputes of material fact regarding the motives for the plaintiff's non-renewal. The court found sufficient evidence to support the plaintiff's claims of retaliation under Title IX and the Whistleblower Act, but dismissed claims of malicious prosecution and defamation, citing lack of evidence and the involvement of public concern. The court also dismissed the plaintiff's claims of intentional infliction of emotional distress and constitutional violations, finding insufficient evidence of extreme and outrageous conduct or constitutional violations by the defendants. The outcome leaves the primary retaliation claims for trial, providing the plaintiff an opportunity to prove the alleged retaliatory motives behind the non-renewal of his contract.

Legal Issues Addressed

Defamation and Public Concern

Application: The court held that the press release about the plaintiff's arrest was not defamatory as it involved a matter of public concern.

Reasoning: The court granted summary judgment in favor of the defendants on Count VI, determining that even if the press release regarding Cass's arrest was published with malice, it involved a matter of public concern.

Intentional Infliction of Emotional Distress

Application: The plaintiff's claim for intentional infliction of emotional distress was dismissed due to lack of extreme and outrageous conduct by the defendants.

Reasoning: The court found that the defendants' police conduct, while ill-advised, did not meet the threshold of extreme and outrageous behavior.

Malicious Prosecution

Application: The court found no sufficient evidence for malicious prosecution claims against the school and police officials.

Reasoning: Cass's claims related to his 2015 arrest, including malicious prosecution against all defendants except Principal Mizoguchi, do not survive summary judgment.

Massachusetts Whistleblower Act

Application: The plaintiff claims his non-renewal was retaliatory under the Massachusetts Whistleblower Act for disclosing improper fundraising practices.

Reasoning: Cass's state whistleblower claim under the Massachusetts Whistleblower Act parallels his Title IX claim, asserting retaliation for disclosing improper fundraising practices.

Retaliation under Title IX

Application: The plaintiff alleges that his contract was not renewed in retaliation for advocating gender equity and raising Title IX concerns.

Reasoning: Cass claims retaliation by the Town of Wayland and Wayland Public Schools for raising concerns about gender equity in athletics, violating Title IX and the Massachusetts Whistleblower Act.

Section 1983 and Massachusetts Civil Rights Act Claims

Application: The plaintiff's claims under 42 U.S.C. § 1983 and the Massachusetts Civil Rights Act failed due to lack of evidence of constitutional violations.

Reasoning: Cass's claim under the Massachusetts Civil Rights Act (MCRA) also fails due to the absence of a constitutional violation, prompting the Court to grant summary judgment for the Defendants.

Summary Judgment Standards

Application: Summary judgment was denied for some claims due to genuine disputes of material fact regarding the motives for contract non-renewal.

Reasoning: However, genuine disputes of material fact exist, allowing Cass's claims to survive summary judgment.

Tortious Interference with Contractual Relations

Application: The plaintiff alleges that the defendants interfered with his employment contract through retaliatory evaluations.

Reasoning: In a separate claim, Cass alleges intentional interference with his employment contract by Stein, Crozier, and Mizoguchi through a false negative performance review driven by retaliatory intent.