Chacko v. Texas a & M University
Plaintiff Jane Chacko, a Canadian citizen, sued Texas A&M University (TAMU) and several individual defendants for alleged national origin and citizenship discrimination under Title VII, 42 U.S.C. §§ 1981 and 1983. Chacko claimed she was offered a position as Sponsored Student Specialist, obtained a work visa, but was subsequently not hired or terminated due to her non-U.S. citizenship, following complaints from an ISS staff member. The defendants moved for summary judgment, arguing Chacko was never officially hired and that Title VII does not cover citizenship discrimination. The court granted summary judgment for TAMU on the Title VII claim, finding it covers national origin, not citizenship, and also for TAMU on §§ 1981 and 1983 claims due to sovereign immunity. Additionally, the court granted qualified immunity to defendants Gage and Cocanougher. However, summary judgment was denied for defendants Ashworth and Droleskey on the §§ 1981 and 1983 claims in their individual capacities, as genuine issues of material fact remained regarding their discriminatory motives in Chacko's hiring/termination.