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Dixon v. University of Toledo

From April 2008 to December 2012
University of Toledo (Public college or university)
Toledo, OH, United States

Identity of Speakers

  • Crystal Dixon
    Faculty/Staff
    Other

    Crystal Dixon was the interim Associate Vice President for Human Resources at the University of Toledo.

Additional Information

  • Incident Nature:
    Other
  • Incident Responses:
    University administration not protective of speech
  • Incident Status:
    Dismissed
  • No protest Occured
  • Did not involve Speech Codes

Summary

Crystal Dixon was the interim Associate Vice President for Human Resources at the University of Toledo. On April 4, 2008, the Toledo Free Press, a now discontinued weekly newspaper, published an op-ed entitled “Gay Rights and Wrongs: Another Perspective,” which compared the modern gay rights movement to the historic civil rights movement and stated “do not tell me you are ‘tolerant’ or ‘tolerate’ gay people. Stop for a moment to think about how condescending and evil that attitude is.”

Dixon, a self-described conservative Christian, responded to the op-ed by sending the newspaper a letter to the editor, which the newspaper published on April 18, 2008. In the letter, Dixon expressed outrage about the comparison of the gay rights movement and the civil rights movement, stating “I take great umbrage at the notion that those choosing the homosexual lifestyle are ‘civil rights victims.’” Dixon further wrote “There are consequences for each of our choices, including those violate God’s divine order . . .[i]t is base human nature to revolt and become indignant when the world or even God Himself, disagrees with our choice that violates his divine order.” She did not identify herself by name but referred to herself as “an alumnus of the University of Toledo’s Graduate School, an employee and business owner” and used her University photograph.

After Dixon’s letter was published, the University immediately placed her on administrative leave. In early May, the Toledo Free Press published an op-ed by Lloyd Jacobs, the President of the University of Toledo, in which he condemned Dixon’s letter and stated that the University had an Equal Opportunity Policy that forbids discrimination on the basis of sexual orientation. Jacobs also identified Dixon as an employee of the University.

On May 5, 2008, Jacobs convened a disciplinary hearing to discuss Dixon’s letter. During the hearing, Dixon read a prepared statement in which she claimed that she had never discriminated against anyone on the basis of their sexual orientation and complained about the responses that her letter had generated. On May 12, 2008, Dixon was terminated. The termination letter stated: “the public position you have taken in the Toledo Free Press is in direct contradiction to University policies and procedures as well as the Core Values of the Strategic Plan which is mission critical.”

On December 1, 2008, Dixon filed a § 1983 action in the U.S. District Court for the Northern District Ohio against the University of Toledo, Jacobs, and William Logie, the Vice President for Human Resources and Campus Safety. In her complaint Dixon alleged that the University and the individual defendants had violated her First and Fourteenth Amendment rights. On February 6, 2012, the district court granted the defendants’ motion for summary judgment, finding that Dixon was a policy-maker and that her statements had the potential to disrupt the Human Resources Department, injure the University’s interest in promoting diversity, and subject any future personnel decisions that she was involved in to undue criticism. On December 17, 2012, the Sixth Circuit Court of Appeals affirmed the District Court’s ruling finding that the government’s interests outweighed Dixon’s interests as a matter of law.