UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MEHDI MOINI, Plaintiff, v. THOMAS J. LEBLANC, in his official Case No. 1:19-cv-03126 (TNM) capacity as President, George Washington University, Defendant. MEMORANDUM OPINION AND ORDER George Washington University (the “University”) denied tenure to Mehdi Moini, Ph.D. Moini, proceeding pro se, alleges that this decision violated Title VII of the Civil Rights Act of 1964 (“Title VII”), the D.C. Human Rights Act (“DCHRA”), and 42 U.S.C. § 1981. He also claims that the University breached its contractual obligations. University President Thomas J. LeBlanc (“the President”) moves to dismiss the Complaint. The Court finds that Moini’s claims under Title VII and the DCHRA are time-barred, so it will dismiss them. But the Court will not dismiss his other claims. Given the liberal pleading standards for pro se plaintiffs, Moini has alleged enough facts at this stage to proceed with his § 1981 claim and his contract claims. The Court will thus grant in part and deny in part the President’s motion to dismiss. I. Moini describes himself as “a Middle Eastern (Iranian)” individual. Compl. ¶ 5, ECF No. 1. He holds a doctorate in chemistry from Michigan State University. Id. ¶ 24. From 1987 to 2014, he held several academic and research positions, including at the Smithsonian Institution. Id.; Compl. Exs. at 282,1 ECF No. 1-5. He joined the faculty of George Washington University in 2014 as a tenure-track associate professor in the Department of Forensic Sciences. Compl. ¶ 25. The appointment was for a period of three and a half years, so he would receive a tenure decision no later than June 2017. Id. In accepting the position, Moini agreed to “the conditions stated in the Faculty Code and Faculty Handbook.” Id. ¶ 12. The Code contains the criteria for tenure. Id. ¶ 13. As of 2015, it provided that “tenure is reserved for members of the faculty who demonstrate excellence in scholarship, teaching, and engagement in service and who show promise of continued excellence.” Id. The lynchpin of this case is the “excellence in teaching” criterion. Moini alleges that he built a strong record in all areas—scholarship, teaching, and service. Id. ¶¶ 28–30. For example, he published nine peer-reviewed papers, collaborated with federal agencies, and gave presentations at local schools. Id. ¶¶ 28–29. And many colleagues and students have praised his teaching. Id. ¶ 30. But he acknowledges that student evaluations from a graduate seminar he taught were “relatively poor” and “below departmental averages.” Id. ¶¶ 2, 31. This seminar is mandatory for graduate students, and Moini describes it as “quite demanding.” Id. ¶¶ 2, 10. For a time, he co-taught the course with a colleague, Professor Rowe, who “received similar negative student evaluations.” Id. ¶ 31. Soon after Rowe stepped down as a co-instructor, he received a promotion to Department Chair. Id. ¶¶ 26, 33. Moini submitted his tenure application in September 2016, which triggered a multi-step review process. Id. ¶¶ 17, 32. First, a committee of tenured faculty in ...
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