Dalia Rashdan (Mohamed) v. Marc Geissberger

Dalia Rashdan (Mohamed) was enrolled in a dentistry program for international students at the University of the Pacific. She appeals from the district court’s grant of summary judgment in favor of the University and several instructors and administrators on her claim of national origin discrimination in violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000d et seq. We join our sister circuits in holding that the McDonnell Douglas framework for disparate treatment claims under Title VII applies to Rash-dan’s Title VI claim. Under this analysis, Rashdan’s claim fails because she did not establish a prima facie case of national origin discrimination.

Background and Procedural History

Rashdan, an Egyptian dentist, was enrolled in a two-year International Dental Studies Program to credential her for practice in the United States. Three months before graduation, Rashdan followed her clinical supervisor’s instructions to seat a crown, but the procedure was unsuccessful. After the head of the restorative dentistry program, Dr. Geissber-ger, heard from a colleague about the failed crown seating, he told Rashdan— within earshot of other faculty, students, and…