Ohio State University must stand trial for its decision to deny a young woman admission to a doctoral program because she submitted reasonable evidence that she was turned away because she has Crohn's disease, a federal appeals court ruled Monday.
The decision by a divided panel of the U.S. Court of Appeals for the Sixth Circuit overturned a federal magistrate judge's March 2013 ruling rejecting Caitlin Sjöstrand's claims that the university had discriminated against her "by reason of" her physical disability.
Sjöstrand's undergraduate grade point average (which she accumulated in earning a bachelor's degree in two and a half years at Ohio State's Newark campus) and GRE scores easily met the requirements for admission to Ohio State's school psychology doctoral program in 2009. But she was the only one of seven applicants to the program who was rejected, the appeals panel found; one of the candidates the university admitted over her had lower grades and test scores and misspelled "enrollement" and "commnuty" on the application.
Ohio State officials asserted that they had rejected Sjöstrand for a legitimate reason: she appeared to be a better fit for the university's counseling program, because she seemed more interested in counseling adults than children and had identified a counseling professor as a potential mentor.
But lawyers for Sjöstrand argued that Ohio State's proffered reasons for engaging in apparent discrimination were pretextual -- and the appeals court found the evidence she presented on that front persuasive enough to require Ohio State to defend itself against it.
In the interview with officials of the school psychology program, Sjöstrand testified, the Ohio State representatives did not ask the applicant any questions -- "not a single one -- about any of the five putative reasons for Sjöstrand's rejection," the court said.
"That omission is important evidence that these putative reasons were actually pretextual ones, and that the real reason for Sjöstrand's rejection was the one that [Ohio State professors] discussed at length in Sjöstrand's interviews: her Crohn's disease," the appeals panel wrote. The majority of the three-judge panel concluded that Sjöstrand should have a chance to make her case before a jury.
A dissenting judge in the case challenged the majority's view that Ohio State did not offer sufficient reasons for rejecting Sjöstrand. The applicant, not Ohio State officials, raised the subject of her Crohn's disease in the interview, the dissenting judge wrote, and Ohio State "relied upon legitimate, articulated reasons to deny Sjöstrand admission to the graduate program."
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