Penny Jackson, a Black woman and veteran, enrolled in the University of Texas Southwestern Medical Center (UTSMC) medical program in 2021 with a full scholarship contingent on strong academic performance. She failed two courses in her first semester, resulting in the revocation of her scholarship and placement on academic warning. In her second semester, she failed three additional courses, including a final exam taken with accommodations. UTSMC dismissed her from the program. Jackson sued in federal court, alleging race discrimination under Title VI, disability discrimination under the ADA and Rehabilitation Act, and failure to provide reasonable accommodations. The district court granted summary judgment for UTSMC, and Jackson appealed to the Fifth Circuit.
The Fifth Circuit applied the McDonnell Douglas burden-shifting framework to the race discrimination claim and found Jackson failed to establish a prima facie case. The court reasoned that she did not cite specific evidence showing she was a qualified individual after failing five courses and nearly four final exams. Furthermore, she failed to identify similarly situated students outside her protected class who were treated more favorably; isolated discrepancies in grading or a male student retaining a scholarship did not meet the legal standard. Regarding disability discrimination, the court held that a qualified individual must satisfy the program's essential eligibility requirements with or without reasonable accommodations. Since Jackson failed her Respiratory final exam despite having accommodations and failed other courses, she could not demonstrate she met these essential requirements. On the failure-to-accommodate claim, the court ruled that merely informing the school of a disability or veteran status is insufficient to provide actual knowledge of a need for specific accommodations. The court noted that UTSMC provided accommodations after Jackson submitted the required forms in March 2022, and the delay was caused by her provider's failure to respond to clarification requests, not by the school's refusal to accommodate.
The decision affirms the district court's dismissal of Jackson's case, leaving the school's academic dismissal intact. It reinforces the legal standard that plaintiffs must provide specific evidence of their qualifications and clearly identify the need for accommodations to survive summary judgment. The ruling clarifies that academic institutions are not liable for dismissal based on academic deficiencies unless the plaintiff can prove they were otherwise qualified and that the dismissal was driven by discriminatory intent or a failure to provide necessary accommodations.
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