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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LISA CALVENTE, 

Plaintiff, 

v. 

SALMA GHANEM and DEPAUL 

UNIVERSITY, 

Defendants. 

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Case No.: 1:20-cv-03366 

Judge John Robert Blakey 

DEFENDANTS’ COMBINED MOTION FOR SUMMARY JUDGMENT 

Defendants, Salma Ghanem (“Dr. Ghanem”) and DePaul University (“DePaul” or 

“University”), by their attorneys, Cozen O’Connor, hereby moves for summary judgment on all 

claims raised by Plaintiff Lisa Calvente (“Plaintiff”) pursuant to Rule 56 of the Federal Rules of 

Civil Procedure and Local Rule 56.1. In support of their motion, the Defendants submit their 

Statement of Undisputed Material Facts and Memorandum of Law and respectfully state as 

follows: 

1. Plaintiff is a former tenure-track Assistant Professor in DePaul’s College of 

Communication (“College”), who filed this lawsuit challenging her denial of tenure and 

termination of employment. Plaintiff alleges claims of employment discrimination and retaliation 

under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e, et seq. (“Title VII”) against 

DePaul; and 42 U.S.C. §1981 (“Section 1981”) against DePaul and Dr. Ghanem; and a claim of 

breach of contract against DePaul. 

2. According to her own testimony, Plaintiff has no evidence that would permit a 

reasonable factfinder to conclude that Plaintiff was denied tenure because of her race or in 

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retaliation for her complaints of discrimination, and has no evidence that would DePaul breached 

any contract to her. 

3. The undisputed material facts demonstrate that Plaintiff cannot present a prima 

facie case of discrimination under Title VII or Section 1981 because she cannot demonstrate that 

she was qualified for tenure or that similarly situated faculty members outside of her protected 

class were treated more favorably. Even assuming Plaintiff could present a prima facie case of 

discrimination, Defendants have articulated legitimate non-discriminatory reasons for denying 

Plaintiff’s tenure application, including deficiencies identified by her peers in the areas of 

teaching, research, and service, and Plaintiff’s outright refusal to adopt recommendations on how 

to improve. The record is replete with evidence demonstrating that at every step of the multilevel tenure review – during which Plaintiff availed herself of all the procedural protections built 

into the process – faculty peers engaged in a careful evaluation of Plaintiff’s application for 

tenure and promotion, and determined that although Plaintiff possessed many strengths and 

achievements, her “very good” record fell short of the “excellent” qualifications required for 

tenure. Plaintiff cannot present evidence that the Defendants’ legitimate reasons are a pretext for 

discrimination, and therefore, her discrimination claims fail as a matter of law. 

4. The undisputed material facts also show that Plaintiff cannot demonstrated a case 

for retaliation under Title VII or 42 U.S.C. §1981 because there is no evidence Plaintiff’s 

complaints of discrimination were the “but for” cause of her tenure denial. Rather, Plaintiff’s 

tenure evaluation was subjected to multiple levels of careful review by 30 different faculty 

members, including Dr. Ghanem, who articulated numerous non-retaliatory reasons in support of 

the tenure decision, and who, in the same tenure cycle as Plaintiff, also granted tenure to another 

faculty member who complained of discrimination. 

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5. Finally, the undisputed material facts demonstrate that Plaintiff cannot 

demonstrate that DePaul breached its Faculty Handbook when it denied her tenure. It is 

undisputed that tenure is not guaranteed at DePaul, and is only granted when, in the academic 

judgment of peer faculty, there is “no reasonable doubt about the faculty member’s demonstrated 

qualifications and continued capacity to contribute to DePaul’s distinctive goals and academic 

mission.” 

6. The bases for the Defendants’ motion are set forth more fully in the 

accompanying Statement of Undisputed Facts and the accompanying Memorandum of Law in 

Support of Defendants’ Combined Motion for Summary Judgment which is incorporated here by 

reference. 

WHEREFORE, Defendants respectfully request that this Court enter an Order granting 

summary judgment in its favor and against Plaintiff, and that Defendants be awarded such other 

and further relief as the Court deems just and proper. 

Dated: November 19, 2021 

Respectfully submitted, 

By: /s/ Anneliese Wermuth 

Attorney for Defendants, Salma Ghanem 

andDePaul University 

Anneliese Wermuth (#6270970) 

Nandini K. Sane 

Cozen O’Connor 

123 N. Wacker Drive, Ste. 1800 

Chicago, IL 60606 

Telephone: 312/474-7876 

Email: awermuth@cozen.com 

Email: nsane@cozen.com 

Attorney for Defendants

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CERTIFICATE OF SERVICE 

The undersigned attorney hereby certifies that on November 19, 2021, she 

electronically filed the foregoing with the Clerk of the United States District Court for the 

Northern District of Illinois using the ECF system, which will send notification of such 

filing to the following counsel of record: 

Fitzgerald T. Bramwell 

Law Offices of Fitzgerald Bramwell 

225 West Washington Street, Ste. 2200 

Chicago, IL 60606 

bramwell@fitzgeraldbramwell.com 

s/ Anneliese Wermuth 

Anneliese Wermuth 

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