Correia v. Jones, 112719 FED8, 18-3625

Docket Nº:18-3625
Opinion Judge:ERICKSON, CIRCUIT JUDGE.
Party Name:Julia Correia Plaintiff - Appellant v. Glenn Jones, Individually, and in his official capacity as Chancelor of Henderson State University Defendant-Appellee
Judge Panel:Before SMITH, Chief Judge, BEAM and ERICKSON, Circuit Judges.
Case Date:November 27, 2019
Court:United States Courts of Appeals, Court of Appeals for the Eighth Circuit
 
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Julia Correia Plaintiff - Appellant

v.

Glenn Jones, Individually, and in his official capacity as Chancelor of Henderson State University Defendant-Appellee

No. 18-3625

United States Court of Appeals, Eighth Circuit

November 27, 2019

Submitted: September 25, 2019

Appeal from United States District Court for the Western District of Arkansas - Hot Springs

Before SMITH, Chief Judge, BEAM and ERICKSON, Circuit Judges.

ERICKSON, CIRCUIT JUDGE.

Julia Correia sued Glenn Jones, the President of Henderson State University, for employment discrimination following her termination. The district court1 granted Jones's motion for summary judgment. Concluding that Correia was an at-will employee at the time of her termination, we affirm.

I. Background

Julia Correia worked at Henderson State University ("Henderson") as the Coordinator of the Center for Language Proficiency ("Center") and Instructor of the English as a Second Language ("ESL") program. Every year, including the 2013- 2014 fiscal year, Correia entered into a year-long employment contract. Her 2013- 2014 contract expired on June 30, 2014, and was not renewed.

In May 2014, Henderson's Board of Trustees passed a budget including Correia's name, title, and position. In June 2014, Glenn Jones, Henderson's President, received a whistleblower tip alleging mismanagement at the Center. After an unofficial audit verified the allegation, Arkansas's Legislative Joint Auditing Committee ("LJAC") conducted a formal audit. Correia was placed on paid administrative leave on July 7. On October 3, Henderson closed the Center, and Correia's contract was not renewed.

On December 16, 2014, LJAC's audit report became public information. That morning, Jones sent an email to all Henderson staff and faculty and encouraged them to review an attached copy of the report. Local news articles quoted Jones and included findings from the report. Correia does not dispute many of the report's findings and agrees that the report was the result of an independent investigation, not the work of anyone at Henderson.

Correia requested a name-clearing hearing on August 15, 2017. On August 22, Correia filed a complaint under 42 U.S.C. § 1983 and the Arkansas Civil Rights Act of 1993. Competing motions for summary judgment were made by Correia and Jones. Finding Jones entitled to qualified...

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