Judge Sarah Geraghty, nominated by President Biden to the Northern District of Georgia, rejected state officials’ attempts to dismiss a race discrimination claim brought by a Black former graduate student at the University of Georgia. Instead, Arebe Taylor will have the opportunity to prove that two university officials improperly dismissed him from a graduate program and committed other misconduct based on his race. The October 2022 decision was in Taylor v Board of Regents.
What’s the case about?
Taylor, a naturalized citizen from Sierra Leone, enrolled as a public health graduate student at the university. He “was generally academically successful” during his years in the program. Despite repeated requests, two supervisory faculty members failed to appoint a faculty advisory committee for him and for another Black student in accord with university guidelines. They did appoint one, however, for a white student in his cohort.
After disagreements about Taylor’s performance on a comprehensive exam and other issues, the two faculty members (Harmon and Feldman) dismissed Taylor from the program. Administrative efforts to appeal the dismissal failed. Taylor filed a federal suit against Harmon, Feldman, and other university officials, seeking damages and other relief. In addition to his race discrimination claims, Taylor brought various due process claims against the university. All the defendants moved to dismiss the case as a matter of law, asserting that Taylor had failed to allege sufficient facts to prove any of his claims.
How did Judge Geraghty rule and why is it important?
Although she agreed to dismiss due process and other claims by Taylor in a comprehensive opinion, Judge Geraghty upheld his right to pursue his race and national origin discrimination claims for damages against Harmon and Feldman. In particular, Judge Geraghty rejected a dangerous assertion about the use of “comparators,” like the white student who received a faculty advisory committee while Taylor did not, in discrimination cases. Defendants claimed, as a few district courts have held, that Taylor had to include specific details about the basis for the comparison in his complaint, or otherwise the case must be dismissed. This would make it much harder to bring bias lawsuits. After careful analysis, Judge Geraghty rejected this assertion as flatly “inconsistent” with appellate precedent.
Instead, she explained, Taylor’s complaint under 42 U.S.C. 1981 need only include “well-pleaded factual allegations” that “plausibly suggest” that he “suffered an adverse…action due to intentional racial discrimination.” Taylor’s complaint met this standard, she went on, largely through allegations of disparate treatment with white students. Although the university faculty might prevail later in the case after discovery, Judge Geraghty explained, the law clearly allowed Taylor to proceed and try to prove his discrimination claims.
In addition to upholding this important right for Arebe Taylor, Judge Geraghty’s opinion is important to other discrimination victims as well by rejecting the University’s attempted dangerous limitation on bias claims. Prior to becoming a judge, Sarah Geraghty had served as senior counsel for the Southern Center for Human Rights, illustrating President Biden’s effort to promote professional diversity in his judicial nominations. Her ruling in this case serves as a good example of an important decision by a fair-minded federal judge nominated by President Biden and a reminder of the importance of confirming more such judges to our federal courts.