UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

STEPHANIE GELDERLOOS, 

 Plaintiff, Case No. 

v. Hon. 

WASHTENAW COMMUNITY COLLEGE; Mag. 

ROSE BELLANCA, President of Washtenaw 

Community College in her individual and 

official capacities; and WILLIAM ABERNETHY, 

Interim Vice President for Instruction at Washtenaw 

Community College in his individual and official 

capacities, 

 Defendants. 

____________________________________________________________________________ 

DAVID M. BLANCHARD (P67190) 

EDWARD A. MACEY (P72939) 

NACHT, ROUMEL, SALVATORE, 

BLANCHARD & WALKER, P.C. 

Attorneys for Plaintiff 

101 N. Main Street, Ste. 555 

Ann Arbor, Michigan 48104 

(734) 663-7550 

dblanchard@nachtlaw.com 

emacey@nachtlaw.com 

COMPLAINT AND JURY DEMAND 

 

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SUMMARY OF ILLEGAL CONDUCT 

1. The Washtenaw Community College English Department has adopted an 

intentional policy of discriminating against women in its faculty hiring decisions. Plaintiff 

Stephanie Gelderloos is a victim of that policy who is seeking recovery for herself to prevent future 

violations. In particular, she requests injunctive relief prohibiting WCC from using sex as a factor 

to deprive women of faculty positions. 

2. In 2013, Stephanie Gelderloos applied for a full time faculty position after years of 

part-time and temporary teaching assignments at the school. WCC administration tampered with 

the interview selection process for full time faculty position in order to justify hiring a less qualified 

male candidate. WCC refused to hire Ms. Gelderloos because she is a woman, even though she 

was the most qualified applicant and even though the hiring committee unanimously recommended 

her to the administration for hire. Instead, WCC hired a less-qualified, male candidate based on a 

motivation to increase male representation – a practice that violates state and federal law. 

PARTIES AND JURISDICTION 

3. Plaintiff Stephanie Gelderloos (“Stephanie” or “Plaintiff”) is a resident of Ann 

Arbor, Michigan in the County of Washtenaw. 

4. Defendant Washtenaw Community College (“WCC” or “Defendant”) is a 

Michigan community college with its principal place of business in Ypsilanti, Michigan in the 

County of Washtenaw. 

5. Defendant Rose Bellanca is employed as the President of Defendant WCC and, on 

information and belief, is a resident of Washtenaw County. 

6. Defendant William Abernethy is employed as the Interim Vice President of 

Instruction of Defendant WCC and, on information and belief, is a resident of Washtenaw County. 

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7. Defendants Bellanca and Abernethy are the official policymakers on decisions to 

hire faculty for WCC. 

8. Plaintiff brings this action to remedy violations Title IX of the United States 

Education Amendments of 1972, 20 U.S.C. §§ 1681–88, the Elliott-Larsen Civil Rights Act, MCL 

37.2101, et seq., the Michigan State Constitution, Article 1 § 26, and the Equal Protection Clause 

of the United States Constitution. 

9. Apart from the claims raised in this Complaint, Plaintiff has also filed a charge of 

discrimination with the Equal Employment Opportunity Commission (“EEOC”), which is still 

pending. In response to the EEOC Charge, the Commission has issued a finding that there is cause 

to believe illegal discrimination did occur. The case is now under further review by the Department 

of Justice. Upon the issuance of a “right to sue” letter by the Department of Justice, Plaintiff 

intends to amend her Complaint to add a claim under Title VII of the Civil Rights Act based on 

the same nexus of facts at issue in this action. 

10. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 because 

this action involves a claim under a federal statute, 42 U.S.C. § 1981. 

11. Jurisdiction of the state law claim is founded upon the pendant or supplemental 

jurisdiction of the Court pursuant to 28 U.S.C. § 1367. 

12. Venue is proper in the Eastern District of Michigan pursuant to 28 U.S.C. § 1391, 

as it is the district where the Plaintiff lives, where the Defendant’s principal place of business is 

located, and where the events giving rise to Plaintiff’s claims took place. 

13. The amount of controversy is in excess of $75,000, exclusive of interest, costs, 

attorney fees and punitive damages. 

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COMMON FACTUAL ALLEGATIONS 

14. Ms. Gelderloos was employed by WCC for approximately nine years as an 

instructor in the English Department. She held part-time, adjunct, and temporary full-time 

instructor positions during her time with WCC. 

15. WCC’s policies provide that, when hiring new faculty, the hiring supervisor, 

executive officer, or dean will appoint a selection committee to carry out the interview process. 

The general function of the committee is to recommend the most suitable candidate for hire. After 

evaluating each candidate, the committee recommends a candidate to the administration, and the 

administration hires the recommended candidate. 

16. It was the previous practice of the English Department to follow these policies. 

17. When committee members agree on a top candidate, the selection committee’s 

practice was to recommend that one candidate for hire to the Department leadership and 

administration. 

18. When a permanent full-time position in WCC’s English Department was posted in 

April of 2013, Ms. Gelderloos applied and was selected for an interview. 

19. The posting listed minimal qualifications: a Master’s degree in a related field, the 

equivalent of two years successful teaching experience, preferably at the community college level, 

and demonstrated experience in developing instructional materials in writing. 

20. Ms. Gelderloos exceeded these minimal qualifications with her nine years’ teaching 

experience at WCC and her academic achievements at both the undergraduate and graduate levels. 

21. Ms. Gelderloos’ first interview took place on June 18, 2013. 

22. Ms. Gelderloos received top scores from the hiring committee. 

23. According to Carrie Krantz, WCC’s English Department Chair, Ms. Gelderloos’ 

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teaching demonstration was by far the best demonstration the committee saw during the hiring 

process. 

24. Not all members of the selection committee retained interview notes 

25. WCC policy requires all selection committee members to retain notes. 

26. All members rated Ms. Gelderloos very highly. 

27. One committee member wrote “YES!!” and drew a star next to Ms. Gelderloos’ 

name and “NO!” and “MAYBE” next to all other candidates’ names. 

28. Consistent with policy and practice, Defendants’ interviewing committee 

unanimously recommended Ms. Gelderloos to the administration for hire as the top candidate for 

the position. 

29. After the interviewing committee submitted their recommendation, the 

administration requested that the committee re-submit its recommendation to include two 

additional names for its consideration. 

30. The reason for changing the practice after Ms. Gelderloos was selected was that 

administration wanted a male candidate they were free to hire, despite Ms. Gelderloos being more 

qualified. 

31. Mr. Abernethy, the Interim Vice President of Instruction, and Dena Blair, the 

Interim Dean, interviewed Ms. Gelderloos and the two additional, less qualified candidates during 

second-round interviews. 

32. Defendants ultimately hired a less qualified male for the position. 

33. WCC’s administration sought to hire a male candidate to increase the English 

Department’s “diversity” and chose the hire him specifically because he is a male. 

34. Mr. Abernethy has repeatedly and publicly stated that there are not enough men in 

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the English Department. 

35. After the decision, many hiring committee members expressed disappointment that 

Defendants hired the less qualified male instead of Ms. Gelderloos. For example, upon receiving 

word about the hire, Ms. Shepherd wrote in an email, “What happened to our first choice????” and 

“I’m pissed about this hire.” Ms. Krantz added, “Another unhappy department member . . .” and 

“I’m heartsick.” Finally, Ms. Kissel wrote “It is frustrating . . . I mentioned the issue to Stuart [the 

Previous V.P. for Instruction], and he noted that he could see that Stephanie would have a hard 

time getting hired by Bill [Abernethy].” 

36. Ms. Gelderloos was significantly more qualified for the position than the male 

candidate hired. 

37. For example, the hire’s cumulative undergraduate GPA was 2.563, while Ms. 

Gelderloos graduated Magna Cum Laude with a 3.70 GPA. Similarly, the hire’s Master’s GPA 

was 3.80 while Ms. Gelderloos earned a 3.97. 

38. Ms. Gelderloos also received significantly higher ratings from the interview 

committee. She was the only candidate to score a 5 out of 5 on the ENG FT Review Sheet. The 

male candidate, by comparison, scored a 3. 

39. Defendants gave preference to the male candidate not because he was the most 

qualified candidate but because he is male. 

40. WCC’s refusal to hire Ms. Gelderloos was substantially motivated by the fact that 

she is a female. 

41. In response to the EEOC’s proposals following the cause finding, WCC has refused 

to reinstate or appoint Ms. Gelderloos to the position that she should have held but for the illegal 

discrimination. 

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COUNT I – Title IX, 20 U.S.C. §§ 1681–88 

DISCRIMINATION ON THE BASIS OF SEX 

42. Under Title IX of the Education Act Amendments of 1972 (20 USC §§ 1681–88), 

an educational institution may not exclude any person, on the basis of sex, from participation in 

any education program or activity receiving federal financial assistance, or deny benefits on the 

basis of sex or subject that person to sex-based discrimination. This includes employees as well as 

students. 

43. Defendants operate an education program receiving federal financial assistance. 

44. Ms. Gelderloos was subjected to discrimination on the basis of sex when she was 

denied an employment opportunity because she is female. 

45. As a result, Plaintiff was harmed, and continues to be harmed, in that she has 

suffered economic and non-economic loss, including but not limited to lost wages, damage to 

professional reputation, emotional distress, outrage, and humiliation. 

COUNT II – Elliott-Larsen Civil Rights Act, MCL 27.2101 

DISCRIMINATION ON THE BASIS OF SEX 

46. Plaintiff hereby realleges and incorporates the previous paragraphs by reference. 

47. Defendants’ failure to hire Ms. Gelderloos was motivated, in substantial part, by 

the fact that Ms. Gelderloos is female. 

48. As a direct and proximate result of Defendants’ discriminatory conduct Plaintiff 

was harmed, and continues to be harmed, in that she has suffered economic and non-economic 

loss, including but not limited to lost wages, damage to professional reputation, emotional distress, 

outrage, and humiliation. 

COUNT III – Michigan Constitution, Article 1 § 26 

DISCRIMINATION ON THE BASIS OF SEX 

49. Plaintiff hereby realleges and incorporates the previous paragraphs by reference. 

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50. Under the Michigan Constitution, the state (which includes community colleges) 

“shall not discriminate against, or grant preferential treatment to, any individual or group on the 

basis of race, sex, color, ethnicity, or national origin in the operation of public employment, public 

education, or public contracting.” 

51. In the operation of an entity providing public education, Defendants discriminated 

against Ms. Gelderloos on the basis of sex. 

52. As a result, Plaintiff was harmed, and continues to be harmed, in that she has 

suffered economic and non-economic loss, including but not limited to lost wages, damage to 

professional reputation, emotional distress, outrage, and humiliation. 

COUNT IV – 42 USC § 1983 

VIOLATION OF EQUAL PROTECTION CLAUSE 

53. Plaintiff hereby realleges and incorporates the previous paragraphs by reference. 

54. Defendants’ actions in refusing to hire Ms. Gelderloos on the basis of her sex 

abridge her right to equal protection of the laws in violation of the Fourteenth Amendment to the 

U.S. Constitution. 

55. Defendants’ actions were taken intentionally and based on Ms. Gelderloos’ sex. 

56. As a result, Plaintiff was harmed, and continues to be harmed, in that she has 

suffered economic and non-economic loss, including but not limited to lost wages, damage to 

professional reputation, emotional distress, outrage, and humiliation. 

RELIEF REQUESTED 

WHEREFORE, Plaintiff respectfully requests that this Court issue an injunctive order for 

reinstatement of Stephanie Gelderloos to the full-time position and prohibiting WCC from taking 

sex into account in future hiring decisions, and requests recovery for compensatory and other 

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damages in an amount to be determined at trial together with costs, punitive damages, exemplary 

damages, interest, attorney’s fees, statutory penalties, and any other relief at law or equity that this 

Honorable Court deems just and proper. 

Respectfully submitted, 

NACHT, ROUMEL, SALVATORE, 

BLANCHARD & WALKER, P.C. 

s/ David M. Blanchard 

David M. Blanchard (P67190) 

Attorney for Plaintiff 

101 N. Main Street, Ste. 555 

Ann Arbor, MI 48104 

(734) 663-7550 

Dated: August 21, 2014 dblanchard@nachtlaw.com

DEMAND FOR JURY TRIAL 

Now Comes Plaintiff, Stephanie Gelderloos, by and through her attorneys, Nacht, Roumel, 

Salvatore, Blanchard & Walker, P.C., and hereby demands a trial by jury in the above captioned 

matter.

Respectfully submitted, 

NACHT, ROUMEL, SALVATORE, 

BLANCHARD & WALKER, P.C. 

s/ David M. Blanchard 

David M. Blanchard (P67190) 

Attorney for Plaintiff 

101 N. Main Street, Ste. 555 

Ann Arbor, MI 48104 

(734) 663-7550 

Dated: August 21, 2014 dblanchard@nachtlaw.com

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